Switzerland · 10 min read
How to Start a Swiss VASP
Exchange, transfer and custody models for crypto businesses in Switzerland, and which route each one triggers.
Switzerland has no single "VASP licence". The applicable route depends on the business model.
Model 1 — Exchange and brokerage
Exchanging crypto-assets against fiat or other crypto-assets for clients is financial intermediation under AMLA. Without a prudential licence, SRO affiliation is required.
Model 2 — Transfer and wallet services
Transferring crypto on behalf of clients is generally financial intermediation. FINMA Guidance 02/2019 applies the travel rule strictly.
Model 3 — Custody
- Segregated custody where assets are attributable to individual clients at all times is generally not deposit-taking.
- Collective custody without segregation may be treated like deposits and require a FinTech or banking licence.
Model 4 — Trading venues for DLT securities
Operating a DLT trading facility requires a separate FINMA authorisation.
Practical steps
- Obtain a legal qualification of your model.
- Incorporate (typically an AG or GmbH) with Swiss management capacity.
- Prepare AML directives, KYC, transaction monitoring and travel-rule processes.
- Apply to an SRO or to FINMA as required.
- Arrange banking for fiat flows — often the hardest commercial step.
Swiss affiliation does not authorise activity in the EU, where MiCA applies.
Official sources
General information, not legal advice. Confirm current requirements with the competent authority.