Regulatory scoping, SRO/FINMA route assessment, AML/CFT framework development and project coordination for crypto, blockchain and token-based financial businesses.
Switzerland does not issue one generic crypto licence. The correct route depends on financial intermediation, client-asset handling, deposits, securities, trading infrastructure and the economic function of the service.
The correct framework follows the economic function of the activity: financial intermediation and AML supervision, deposit-taking, securities/dealer functions, asset management or financial-market infrastructure.
Financial intermediaries subject to the Swiss Anti-Money Laundering Act may be supervised indirectly through a FINMA-recognised self-regulatory organisation where no higher prudential licence applies.
Potential route for qualifying deposit-taking models within the statutory fintech framework. Applicability depends on how client funds/assets are received and used.
Custody, dealing, securities, collective-investment or other regulated financial activity may require a higher-level FINMA permission or supervised structure.
FINMA authorisation under the Financial Market Infrastructure Act applies to qualifying multilateral DLT-securities trading infrastructure and associated custody/settlement features.
Corporate formation and regulatory authorisation are separate layers. A Swiss AG or GmbH can be foreign-owned, but the company must satisfy Swiss corporate representation requirements and then meet any additional SRO or FINMA substance requirements applicable to its activity.
A Swiss AG can be established with one shareholder and a GmbH with one member; individuals or legal entities can hold the ownership. Foreign founders can therefore own the Swiss applicant, subject to beneficial-owner transparency and any regulatory fit-and-proper review.
An AG must have at least one person authorised to represent it who resides in Switzerland. A GmbH must likewise be capable of representation by at least one Switzerland-resident manager or director.
The company’s head office and domicile are recorded in the Swiss commercial register. A registered address is therefore required; whether a staffed operational office is also expected depends on the actual SRO / FINMA route and the functions carried on in Switzerland.
General corporate minimums are CHF 20,000 for a GmbH and CHF 100,000 for an AG. A FINMA-regulated business may face materially different prudential capital, organisation and staffing requirements depending on the licence.
The first layer is the capital of the Swiss legal entity. Additional prudential capital depends on whether the model remains within AML/SRO supervision or triggers a FINMA licence such as a securities-firm, banking, FinTech or market-infrastructure authorisation.
Minimum share capital, fully paid up. This is a corporate-law floor, not a crypto regulatory capital requirement.
Minimum nominal share capital. At incorporation at least 20% must be paid, but not less than CHF 50,000.
SRO affiliation is AML supervision and does not create one standard “Swiss crypto licence” capital number. The exact model and SRO requirements must be checked.
Prudential licences have separate requirements. By example, FINMA publishes at least CHF 10 million fully paid-up minimum capital for a bank and at least CHF 1.5 million for a securities firm.
Classification of the operating model across AMLA, SRO and FINMA frameworks.
Application and compliance preparation where SRO affiliation is the appropriate supervisory route.
Regulatory and compliance workstream for projects requiring a FINMA licence or approval.
Perimeter and project coordination for multilateral DLT-securities trading, custody or settlement models.
Post-authorisation or SRO compliance support aligned with the actual supervisory route.
Switzerland rewards accurate classification but penalises oversimplification. LEX ARTA treats AMLA, SRO, FINMA prudential rules, securities and DLT infrastructure as a perimeter exercise before the entity and compliance model are committed.
The legal route is derived from what the platform actually does with client assets, orders, deposits, securities and settlement.
Where SRO supervision is the correct route, AML/CFT and governance are built as core operational requirements.
Potential FINMA, securities, asset-management or market-infrastructure triggers are identified before an SRO-only strategy is pursued.
Local legal, audit and SRO/FINMA-facing work is coordinated with appropriately qualified Swiss professionals where required.
Map financial intermediation, custody, deposits, securities and DLT functions.
Determine SRO, FINMA or market-infrastructure pathway.
Define entity, governance, local substance and compliance responsibilities.
Build AML/CFT, business, governance, technology and risk documentation.
Support SRO/FINMA interaction, audit and ongoing maintenance.
Professional fees depend on whether the project requires SRO membership, a FINMA-authorised structure, DLT market-infrastructure work or a mixed perimeter analysis. Swiss counsel, audit firms, SRO/FINMA fees, local personnel, office, capital, banking and technology costs are separate unless expressly included.
No. VQF is a FINMA-recognised SRO. Membership is an AML supervisory route for qualifying financial intermediaries; it is not a universal permission for every crypto business model.
Depending on the activity, deposit-taking, securities/dealer, asset-management, banking or financial-market infrastructure rules may apply. The exact trigger must be assessed from the operating model.
It is a FINMA-licensed financial market infrastructure for qualifying multilateral trading of DLT securities and certain associated custody/settlement functions under FinMIA.
No. Switzerland is outside the EU/EEA; Swiss regulatory status does not replace MiCA authorisation for EU market access.
Where Swiss law requires locally qualified legal or audit input, LEX ARTA coordinates the project with appropriately qualified Swiss professionals.
Start with economic-function and AML/FINMA perimeter analysis before presenting the project as an SRO or “crypto licence” case.
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