Crypto Banking & Digital Asset Regulation in Switzerland: The FINMA Banking Route

Switzerland licenses genuine crypto banks. Two pure-play blockchain providers, SEBA Crypto AG (later renamed AMINA Bank AG) and Sygnum AG, received the country's first bank and securities-dealer licences in 2019, and a dedicated legal framework, the DLT Act, has since cemented Switzerland's position as a jurisdiction where digital assets can be held, traded and issued inside a regulated banking perimeter. This guide explains the institutional route: how the Swiss Financial Market Supervisory Authority (FINMA) authorises crypto banking, the three licence tiers available, the DLT Act and its bankruptcy protections, and the current rules on stablecoins and digital asset custody.

By Magnus Müller · Reviewed by Magnus Müller · Last updated: 2026-06-14

Crypto banking in Switzerland at a glance

Crypto banking in Switzerland is the institutional activity of taking public deposits, holding digital assets in collective custody, trading distributed-ledger (DLT) securities, or issuing stablecoins inside a FINMA-supervised banking perimeter. FINMA supervises and licenses banks, securities firms and DLT trading facilities, while the legislation, including the DLT Act, is set by the Federal Council (FINMA, FinTech authorisation overview, Federal Council, DLT Act in force).

There are three relevant authorisation tiers for operators: the full banking licence (the route the first Swiss crypto banks took), the lighter FinTech licence under Article 1b of the Banking Act, and the DLT trading facility licence created by the DLT Act. Each tier carries different deposit limits, restrictions and depositor-protection consequences, and the right choice depends on whether you take deposits, custody assets at scale, or operate a trading venue. To see how Switzerland sits against other options, compare crypto-license jurisdictions and review how crypto licensing works worldwide.

What "crypto banking" means here (institutional scope)

This page addresses operators, not consumers. "Crypto banking" here means deposit-taking, collective custody of crypto assets, trading of DLT securities and stablecoin issuance carried out under a FINMA banking-tier authorisation, the activities that turn a fintech into a regulated financial institution. It is the bank and securities-firm intent, distinct from the lighter route built on self-regulatory organisation (SRO) membership.

If you are a smaller VASP relying on AML affiliation rather than a banking authorisation, the relevant analysis sits with Switzerland's FINMA and SRO licence paths instead. This guide deliberately owns the bank-grade end of the spectrum: the institutions that custody at scale, trade DLT securities, or take public deposits.

Who regulates and legislates

FINMA is the supervisor and licensing authority for banks, securities firms and DLT trading facilities. It examines operational-risk controls, governance and IT/cyber resilience, and it issues Guidance notices that set supervisory expectations (FINMA, FinTech authorisation overview).

The legislative and policy layer sits above FINMA. The Federal Council and the Federal Department of Finance set the law, including the DLT Act (Federal Council, DLT Act in force). The State Secretariat for International Financial Matters (SIF) sets policy, and Basel/BIS prudential standards inform how crypto exposures are treated for capital purposes.

Do you need a banking licence to run a crypto bank in Switzerland?

You need a banking licence if you take deposits from the public on a professional basis, or if you take collective custody of crypto assets at scale. The "professional basis" test is the gating question, and Swiss law treats it as met automatically in several situations, but it also carves out narrow cases where no licence is required (FINMA, FinTech authorisation overview).

Getting the trigger right is the single most important early decision, because it determines whether your business model needs a full banking licence, a FinTech licence, or no authorisation at all under the deposit rules. The carve-outs below are narrow and conditional, so they should be confirmed against your exact set-up before you build a product around them.

The professional-deposit trigger (the >20-clients rule)

A banking licence is required when you accept deposits from the public on a professional basis. The assumption that you are acting "on a professional basis" is automatic if more than 20 clients are involved, if client assets are paid into your own accounts, or if accepting client assets features in your advertising (FINMA, FinTech authorisation overview).

In practice this means a crypto business cannot grow a deposit-like or pooled-custody offering past a small circle of clients without confronting the licence question. Once any of these conditions is met, the activity falls inside the banking perimeter and FINMA authorisation becomes the threshold issue.

When no banking licence is needed (the carve-outs)

Swiss law recognises specific situations where no banking licence is required. These carve-outs are narrow and depend on the exact arrangement (FINMA, FinTech authorisation overview):

• Client assets are accepted with a bank guarantee.
• A maximum of CHF 3,000 per person is accepted for explicit product or service purchases.
• Bonds are issued in accordance with statutory requirements.
• Crypto-based assets are stored on individual (segregated) blockchain addresses rather than taken into collective custody.

The last point is central to the institutional custody model: keeping client crypto on segregated individual addresses, rather than pooling it, can keep an activity outside the banking-licence requirement, while collective custody at scale pulls it back inside.

The three FINMA authorisation tiers for crypto banking

Switzerland offers three authorisation routes for crypto banking, and choosing between them is the conversion-critical decision for any operator. The full banking licence is the heaviest and most capable, the FinTech licence is a lighter "bank lite" category, and the DLT trading facility licence is a financial-market-infrastructure permit for trading tokenised securities. The right tier depends on whether you take deposits, custody assets, or run a trading venue (FINMA, FinTech authorisation overview, FINMA, FinTech licence page).

Full banking licence (Banking Act / FinIA) - the SEBA/AMINA & Sygnum route

The full banking licence is required to take public deposits on a professional basis or to take collective custody of crypto assets at scale. It is the route the first Swiss crypto banks took. Requirements include an adequate organisational structure, fit-and-proper management and owners, robust risk management and internal controls, and minimum capital set by the Banking Ordinance (FINMA, FinTech authorisation overview, FINMA, Innovation and supervision 2019).

The exact minimum-capital figure for a full banking licence is set by the Banking Ordinance and is not stated here because it was not confirmed from a primary source for this guide (see Open questions). This is the most demanding tier, and it carries no statutory cap on the deposits it can take, which is why it suits a fully fledged crypto bank rather than a custody-only operation.

FinTech licence (Art. 1b Banking Act, "bank lite")

The FinTech licence under Article 1b of the Banking Act is a lighter authorisation. A FinTech institution may accept public deposits up to CHF 100 million, or take collective custody of crypto-based assets. Crucially, the deposits it holds may not be invested, and no interest may be paid on them (FINMA, FinTech authorisation overview, FINMA, FinTech licence page).

This tier was designed to let innovative business models hold client funds without the full weight of a banking licence, provided they stay below the CHF 100 million ceiling and respect the no-investment, no-interest constraints. It suits custody-focused and payment-style models more than a deposit-and-lend bank.

The deposit-protection carve-out you must disclose

The FinTech licence comes with a significant consequence for clients. In the bankruptcy of a FinTech institution, client assets are neither privileged nor protected by deposit protection, and clients must be informed of this. The duty is anchored in Article 1b paragraph 4(d) of the Banking Act and Article 7a paragraph 3 of the Banking Ordinance (FINMA, FinTech licence page).

This disclosure obligation is not optional. An operator using the FinTech route must make the absence of deposit protection clear to clients, which materially changes how the offering can be marketed compared with a full bank.

DLT trading facility licence

The DLT trading facility licence is a financial-market-infrastructure authorisation for the multilateral trading of DLT securities. Its distinguishing feature is that it can admit not only financial intermediaries but also companies and natural persons directly to trading, which is unusual for a regulated trading venue. FINMA licensed Switzerland's first DLT trading facility in 2025 (FINMA, FinTech authorisation overview, FINMA, list of crypto services, Federal Council, DLT Act in force).

This tier matters for operators building tokenised-securities marketplaces rather than deposit-taking institutions. It sits alongside, not inside, the banking licences, and reflects the DLT Act's ambition to give tokenised assets a purpose-built trading infrastructure.

Full bank vs FinTech licence at a glance (comparison)

The two deposit-taking tiers differ most clearly on the deposit cap, what can be done with deposits, and what happens to client assets in bankruptcy. The comparison below summarises the distinction (FINMA, FinTech authorisation overview, FINMA, FinTech licence page).

Across both routes the same gating triggers apply: a banking-tier authorisation becomes necessary once deposits are taken on a professional basis (more than 20 clients), while the CHF 3,000-per-person purchase carve-out and the segregated-address custody carve-out can keep an activity outside the deposit perimeter entirely.

*[Infographic 1 placed here: Full banking licence vs FinTech licence comparison.]*

The DLT Act: ledger-based securities, the DLT trading facility, and bankruptcy segregation

The DLT Act is the legal backbone that makes Swiss crypto banking and custody attractive. It introduced ledger-based securities into Swiss law, created the DLT trading facility licence category, and, critically, set out express rules for segregating crypto-based assets in bankruptcy so that custodied client crypto can be returned rather than absorbed into a failed custodian's estate (Federal Council, DLT Act in force). Switzerland's framework here sits alongside Liechtenstein's Blockchain Act as one of Europe's earliest purpose-built DLT regimes.

What the DLT Act is and when it took effect

The DLT Act is formally the Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology, often called the "Blockchain Act." It is an umbrella act that amends multiple existing federal laws rather than a single standalone statute. It entered into force in two stages: the provisions enabling ledger-based securities took effect on 1 February 2021, and the Act fully entered into force, including the financial-market-infrastructure provisions, on 1 August 2021 (Federal Council, DLT Act in force).

*[Infographic 2 placed here: DLT Act timeline plus bankruptcy segregation.]*

Ledger-based (DLT) securities explained

Ledger-based securities, also called DLT securities, are uncertificated register securities recognised under the DLT Act since 1 February 2021. They give tokenised securities legal effect, meaning rights can be issued and transferred directly on a distributed ledger with the backing of Swiss law (Federal Council, DLT Act in force).

This recognition is what allows tokenised bonds, shares and similar instruments to exist as genuine securities rather than mere book entries, and it underpins the DLT trading facility category that trades them.

Segregation of custodied crypto in bankruptcy (DEBA)

The DLT Act expressly regulates the segregation of crypto-based assets in the event of bankruptcy, through an amendment to the Federal Act on Debt Collection and Bankruptcy (DEBA). The effect is that properly segregated custody assets can be returned to clients rather than falling into the bankruptcy estate of a failed custodian (Federal Council, DLT Act in force).

This segregation rule is the legal certainty that makes Swiss bank custody compelling for institutions: clients gain a clearer path to recovering their assets if a custodian becomes insolvent, provided the assets were correctly held apart.

Switzerland's first crypto banks: SEBA/AMINA and Sygnum

Switzerland was the first major jurisdiction to grant banking licences to pure-play crypto institutions. In 2019, FINMA licensed two blockchain providers as banks and securities dealers, a milestone that established the country's institutional crypto-banking credibility and demonstrated that digital assets could be brought inside the regulated banking system (FINMA, Innovation and supervision 2019).

The 2019 first-ever bank + securities-dealer licences

In 2019, FINMA granted two pure-play blockchain service providers each a licence to operate as a bank and securities dealer for the first time: SEBA Crypto AG (based in Zug, later renamed AMINA Bank AG) and Sygnum AG (based in Zurich). Both serve institutional and professional clients (FINMA, Innovation and supervision 2019).

These two institutions remain the reference points for the full-banking-licence route. The SEBA-to-AMINA rename is widely reported but postdates the 2019 FINMA item, so it is treated here as reported rather than as a separately confirmed fact (see Open questions).

What FINMA examined before licensing them

Before granting these licences, FINMA applied strict criteria and control processes for operational risk, and it carried out thorough testing of the technological infrastructure for IT and cyber risks around the safe custody of tokens (FINMA, Innovation and supervision 2019).

The lesson for prospective applicants is clear: technology resilience and operational-risk governance are examined in depth, not treated as afterthoughts. A crypto bank's custody and cyber-security architecture is part of the licensing assessment, not a post-authorisation detail.

How are stablecoins regulated in Switzerland?

Stablecoins occupy a high-value and closely watched corner of Swiss crypto regulation. FINMA set out its expectations in Guidance 06/2024, published on 26 July 2024, addressing when a stablecoin counts as a deposit, how the common bank-default-guarantee model works, and the money-laundering and sanctions risks that issuers must manage (FINMA, stablecoins guidance 06/2024). Issuers weighing their structure should also review stablecoin issuer licensing for the cross-jurisdiction view.

When a stablecoin is treated as a deposit

A stablecoin holder normally has a redemption claim against the issuer at any time, and such claims usually qualify as deposits under banking law. That qualification in principle triggers a banking-licence requirement, unless an exception applies (FINMA, stablecoins guidance 06/2024).

This is why stablecoin issuance is rarely a casual fintech activity in Switzerland: the redemption promise tends to pull the product into the banking perimeter unless the issuer structures around it.

The bank default-guarantee model

Many Swiss stablecoin issuers use a default guarantee from a bank, which can mean they do not require a banking licence themselves. FINMA sets minimum requirements for such default guarantees to protect depositors, and it warns that the arrangement creates risks for both stablecoin holders and the guaranteeing bank. Each holder should have an individual claim against the guaranteeing bank (FINMA, stablecoins guidance 06/2024).

The default-guarantee route is therefore a structured alternative, not a loophole. It shifts protection onto a regulated bank under FINMA-set conditions, and the individual-claim requirement is what gives holders enforceable rights.

AML, sanctions and holder-identity duties

FINMA underlines the growing money-laundering, terrorist-financing and sanctions-circumvention risks that arise from the possibility of anonymous transfers of stablecoins, and it flags reputational risk to the Swiss financial centre. Issuers must verify the identity of stablecoin holders as their direct customers (FINMA, stablecoins guidance 06/2024). These obligations sit within the broader AML and KYC requirements that apply across regulated crypto activity.

The holder-identity duty is a defining feature of the Swiss approach: a stablecoin issuer cannot treat downstream holders as anonymous, and must apply customer due diligence to them directly.

Digital asset custody and AML obligations

Custody of client crypto is licence-gated in Switzerland, and FINMA has set out current supervisory expectations for institutions that hold digital assets. The combination of a licence requirement, the DLT Act's segregation rules and dedicated custody guidance is what underpins the Swiss "safe custody" proposition (FINMA, list of crypto services, FINMA, custody guidance 01/2026).

Custody of crypto requires a banking or securities-firm licence

Custody of crypto assets requires a banking or securities-firm licence, and trading of DLT securities requires a DLT trading facility licence or stock-exchange approval. This means an existing Swiss bank can add crypto custody and trading under its banking or securities-firm authorisation, building on its current licence rather than starting from scratch (FINMA, list of crypto services).

For incumbents, this is a meaningful advantage: the path to offering digital-asset services runs through extending an existing supervised licence, with FINMA assessing the added activity.

FINMA Guidance 01/2026 on custody risks

On 12 January 2026, FINMA published Guidance 01/2026 on the risks associated with the custody of crypto-based assets, its latest statement of supervisory expectations for institutions holding client crypto (FINMA, custody guidance 01/2026).

The detailed requirements, including the precise segregation mechanics and the return-in-bankruptcy procedure, are set out in the underlying document rather than the press page, and should be parsed in full before any institution finalises its custody design (see Open questions).

AML scope across all routes

AML obligations apply across all of these routes whenever client assets are handled. That includes payment transactions, asset management, wallet and custody services, fiduciary activity and virtual-currency trading (FINMA, FinTech authorisation overview).

In short, the AML perimeter tracks the activity, not the licence tier. A full bank, a FinTech institution and a DLT trading facility are all expected to apply anti-money-laundering controls wherever they touch client assets.

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Is the Swiss banking route right for your crypto business?

Choosing the Swiss banking route is a decision about business model, scale and risk appetite, not a one-size-fits-all answer. The deposit and custody triggers, the licence-tier restrictions and the disclosure duties all push different models toward different authorisations. The synthesis below maps common models to the right route, using the thresholds already covered rather than introducing new figures (FINMA, FinTech authorisation overview, FINMA, FinTech licence page).

Choosing between full bank, FinTech licence and the SRO route

A deposit-taking crypto bank that wants no cap on public deposits and intends to invest or pay interest needs the full banking licence, the SEBA/AMINA and Sygnum route. A custody-focused or payment-style model that can stay under CHF 100 million and accept the no-investment, no-interest and no-deposit-protection constraints may fit the FinTech licence. A tokenised-securities marketplace needs the DLT trading facility licence. Operators weighing alternatives often compare Switzerland with Dubai VARA licensing before committing.

If your model does not require a banking-tier authorisation at all, for example a smaller VASP relying on AML affiliation, the lighter path is the SRO route covered in Switzerland's FINMA and SRO licence paths. Matching the model to the lightest sufficient authorisation is the core of the decision.

From our practice

In our advisory work on Swiss crypto-banking authorisations, the recurring early misstep we see is operators designing a product first and confronting the deposit trigger second, only to discover that a pooled-custody or deposit-like feature has pushed them into the banking perimeter. The more durable approach is to map the activity against the professional-deposit test and the segregated-address carve-out before committing to an architecture, then choose the lightest authorisation that supports the intended scale. We do not publish application timelines as fixed numbers, because Swiss banking-tier authorisations vary substantially with the applicant's organisation, governance and technology readiness, and any single figure would be misleading.