Regulator / authority
FINMA as a general regulator and VQF, PolyReg, SO-FIT, OAD-FCT, and ARIF as Swiss self-regulatory organizations (SRO) recognized by FINMA
A pragmatic Swiss AML-supervised setup for crypto/fiat payment and exchange, brokerage, and credit businesses via membership in a FINMA-authorized SRO
Regulator / authority
FINMA as a general regulator and VQF, PolyReg, SO-FIT, OAD-FCT, and ARIF as Swiss self-regulatory organizations (SRO) recognized by FINMA
Best for
The best solution for businesses that work in the EEA zone and need a multilicensed solution for crypto, brokerage, payments, and credits
Local presence
Required (Swiss entity)
Substance level
Medium (the company should have a local address, the director should be a local with the necessary qualifications, and a local qualified compliance officer should be hired)
Banking friendliness
Medium
Best fit
One director or board member with sole signatory authority must be a resident of Switzerland. At least one additional board member is required and may be resident either in Switzerland or abroad. The AML Officer must be based in Switzerland. Shareholders may be domiciled abroad.
1 Swiss-based director, 1 board member (Swiss-based or abroad), and 1 AML officer based in Switzerland.
For a Swiss GmbH (Sàrl), minimum share capital is CHF 20,000, fully paid in at incorporation. For a Swiss AG (SA), minimum share capital is CHF 100,000, with at least CHF 50,000 paid in (or 20%, but not less than CHF 50,000). Capital can be injected into crypto, and capital can be used for daily expenses.
Requires a business plan, internal AML/CTF policy, compliance manual, and risk assessment / risk matrix.
Suspicious Activity Reporting (SAR) to MROS is mandatory when there are reasonable grounds to suspect money laundering/terrorist financing, filed using official forms. Audit frequency is risk-based, set by SROs, with periodic audits (every 1-3 years) and more frequent audits for higher-risk models. External audit firm and report to SRO: independent audit firm checks AMLA and SRO rules, submits formal audit report. Practical governance routine: yearly compliance plan, staff AML training log, periodic file reviews, and documented decisions on high-risk clients/PEPs/sanctions hits.
Confirmation that SRO membership is suitable for your business plans, explanations of limitations of SRO-regulated asset management companies.
Set up a Swiss company, inject share capital, Swiss domicile, and interviews with the Swiss-based team.
Preparation of internal AML/CTF policy/compliance manual, business plan, hiring of AML officer, and appointment of AML auditor.
SRO membership application support; the regulator starts review of the application.
Handle SRO-related questions from the regulator and adjust documents.
Operational implementation (compliance & IT tools) and go-live; note: members are expected to start activities within 2 years after acceptance and build substance after go-live.
Swiss SRO membership allows a financial intermediary (including crypto businesses) to operate under the Anti-Money Laundering Act by affiliating with a Self-Regulatory Organization (SRO) that is authorized and monitored by FINMA.
No, SRO members are not directly licensed by FINMA, but are supervised through an SRO (e.g., VQF or SO-FIT) that is itself monitored by FINMA.
Yes, within sandbox limits: Up to CHF 1m (general sandbox limit). Unlimited if structured under specific exceptions (e.g., segregated wallets, institutional clients, 60-day processing, bank guarantee).
Yes. Segregated wallets → unlimited amount. Omnibus wallets → limited to CHF 1m total.
No, securities and derivatives are excluded and require separate licensing.
It's possible, but banks will still run their own due diligence (business model, source of funds, jurisdictions, expected volumes, aml setup), and approval is not automatic.
Indicative timeline: Company setup & structuring ~1 month, SRO review 3-4 months, Operational implementation ~1 month.
Sandbox: CHF 1m deposits. Fintech license: up to CHF 100m. Banking license: unlimited deposits + lending permitted.
Swiss SRO Membership·From CHF 195,000
The registration transfers with the company. The obligations attached to it start the day you own it.
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