FINMA Crypto Licensing
Swiss crypto licence — four pathways.
SRO to full banking. We map the route.
Switzerland regulates crypto and VASP businesses under existing financial market law: AMLA, BankG, and the DLT Act (in force 1 August 2021). The correct pathway depends on deposit volume, custody model, and trading activities. Most crypto businesses begin with SRO membership and upgrade as operations scale. Our Zug Crypto Valley team advises on the full regulatory spectrum.
2–4 mo
SRO membership
6–12 mo
FinTech licence
1 Aug 2021
DLT Act in force
CHF 1M
Sandbox limit
Key Data
FINMA Crypto Licence (VASP) — Key Parameters
Virtual Asset Service Provider authorisation in Switzerland
6–18 mo
Processing timeline
FINMA reviews capital, governance, AML systems, and fit-and-proper requirements.
AMLA
AML compliance required
Anti-Money Laundering Act obligations are mandatory for all VASP licence holders.
CHF 300K+
Minimum capital (FinTech route)
FinTech licence route — lower than full banking licence (CHF 10M+).
VASP / FinTech
Applicable licence type
Depending on activity scope — FINMA advises on the correct category pre-application.
Regulatory Pathways
Four pathways for Swiss crypto
and VASP regulation
Switzerland regulates VASPs and crypto businesses under existing financial market law — not a purpose-built crypto statute. The correct pathway depends on whether you accept public deposits, the volume of those deposits, and whether you operate a trading venue. Most early-stage crypto businesses start with SRO membership.
SRO membership
AMLA Art. 24; GwG
The fastest path for VASPs operating below the threshold for a full FINMA licence. SROs (VQF, PolyReg, ARIF) are FINMA-supervised self-regulatory organisations that admit financial intermediaries and enforce AML/KYC compliance on their behalf. Appropriate for crypto exchanges, wallet providers, and token issuers with limited deposit volumes.
Suitable for: Crypto exchanges (non-custodial or limited custody), token issuers, lower-volume VASPs
FinTech licence
BankG Art. 1b
For crypto and fintech platforms accepting public deposits up to CHF 100,000,000. No interest payment and no investment of deposits permitted. Lighter regulatory burden than a full banking licence (BankG Art. 1a) but more intensive than SRO membership. FINMA directly supervises holders.
Suitable for: Stablecoin issuers, crypto deposit platforms, payment-focused VASPs
DLT trading facility
FinfraG Art. 73a–73f
Purpose-built licence for operating a trading venue for DLT-based securities and crypto assets. Enabled by the DLT Act (in force 1 August 2021). Unlike traditional exchange licences, allows admission of retail participants and non-standard settlement systems. Novel licence type — few precedents yet.
Suitable for: Crypto security exchanges, tokenised-asset trading venues, DLT settlement systems
Full banking licence
BankG Art. 1a
Required for crypto custody banks, stablecoin issuers with interest-bearing accounts, or any VASP accepting public deposits without restriction. Highest capital, most intensive FINMA oversight. SEBA Bank and Sygnum Bank hold this licence as crypto-native banks.
Suitable for: Crypto custody banks, full-service digital asset banks
Swiss DLT Act & VASP regulatory framework — key reference points
Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology. Created the DLT trading facility licence and DLT ledger rights (FinfraG Art. 73a–73f; OR Art. 973d–973i).
Uncertificated securities (Wertrechte) can be registered on a DLT ledger and transferred without a traditional securities depository. Enables legally enforceable tokenisation of claims, participations, and financial instruments.
VASPs accepting crypto assets from clients or holding them in custody are classified as financial intermediaries under AMLA and subject to full AML/KYC obligations regardless of licence type.
FATF Travel Rule requires VASPs to transmit sender and recipient identifying information for transfers above the threshold. Swiss implementation via amended GwG ordinance.
FINMA Circular 2011/1 on AML obligations covers crypto-specific guidance including stablecoin classification and the distinction between payment tokens, utility tokens, and asset tokens.
Platforms accepting public deposits or crypto-assets ≤CHF 1,000,000 are exempt from licensing if funds are not invested, no interest is paid, and depositors are informed in writing of non-supervision and absence of deposit protection. AML obligations still apply via SRO.
AML Obligations
AML compliance for Swiss VASPs
five mandatory components
Under AMLA Art. 2(3), all VASPs accepting crypto assets from clients or holding them in custody are financial intermediaries — regardless of whether they hold a FINMA licence. AML obligations apply to every Swiss crypto business from day one of operations.
01
SRO affiliation or FINMA licence
All VASPs must either hold a FINMA licence (direct supervision) or affiliate with a FINMA-supervised SRO (VQF, PolyReg, ARIF). Operating as a VASP without either is a criminal offence under GwG.
02
KYC programme
Mandatory identity verification for all clients before account opening. Enhanced due diligence for PEPs, high-risk jurisdictions, and transactions above threshold. CDB 20 Form A (UBO declaration) for corporate clients.
03
Travel Rule compliance
For crypto transfers above ~CHF 1,000: transmit originator and beneficiary data to the receiving VASP. Requires integration with Travel Rule solutions (Notabene, Sygna, Shyft, or equivalent).
04
AML compliance officer
Independent from revenue functions. Responsible for AML monitoring, suspicious activity reporting (SAR) to MROS, and annual AML report to SRO or FINMA.
05
Transaction monitoring
Automated blockchain analytics (Chainalysis, Elliptic, or equivalent) for on-chain transaction screening. FINMA expects documented risk-based transaction monitoring for all VASP clients.
Post-FTX FINMA regulatory posture
Following the collapse of FTX in November 2022 and subsequent global regulatory tightening, FINMA has intensified scrutiny of new crypto licence applications — particularly for custodial platforms and stablecoin issuers. Applications are still processed and licences are still granted, but FINMA expects robust governance documentation, experienced management teams, and clearly defined custody and segregation arrangements from the outset. A pre-application discussion with FINMA before formal submission is no longer optional for crypto applications — it is essential.
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