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Token classification ruling
Fix whether your token is a payment, utility or asset token under FINMA practice before you build or raise.
Token classification rulingFinTech & Crypto
in Switzerland.
Switzerland regulates digital assets by what a token does, not what it is called. A payment token, a utility token and an asset token sit under different rules, and the wrong classification at launch is expensive to undo. We position fintech and crypto firms on the right side of FINMA practice from the first ruling onwards.
At a glance
Crypto and payments sit at the core of our flagship financial-regulation practice.
Independent since 2007 · IFLR1000-ranked · offices in Zurich and Zug · one partner per file.
- Core question
- Token classification first
- Usual route
- SRO membership or FINMA licence
- AML
- Mandatory from day one
- Flagship
- Financial regulation since 2014
The challenge
What this sector has to get right in Switzerland
A crypto business entering Switzerland faces three questions before it writes a line of marketing. What are its tokens under the FINMA classification — payment, utility or asset? Does its activity make it a financial intermediary that must affiliate with a self-regulatory organisation, or does it need a full FINMA licence such as a fintech or banking authorisation? And who carries the anti-money-laundering duties from the day the first client is onboarded? Getting these wrong is not a paperwork problem; it determines whether a Swiss bank will open an account and whether the model is lawful at all.
The answers interact. A token-classification ruling from FINMA fixes the regulatory perimeter; that perimeter then decides whether SRO affiliation is enough or a licence is required; and either way an AML framework with a responsible officer, KYC onboarding and transaction monitoring has to be live before launch. A stablecoin or a custody offering adds a further layer, because holding client assets pulls the activity towards banking rules. We sequence this so each decision is made with the next one in view, rather than discovered late.
Because financial regulation has been our specialisation since 2014, the regulated parts of fintech (exchanges, custodians, payment firms, DLT trading venues) are the centre of what we do, not an adjacent service. That matters when a model is novel and the precedent is thin, which in crypto it usually is.
What this desk handles
The services this sector uses most
Each links to the service page itself. Most mandates here combine several; one partner co-ordinates them.
Licensing
Crypto licence Switzerland
Map the authorisation your model needs (SRO affiliation, fintech, securities or banking) and run the application.
Crypto licence SwitzerlandAML
VASP & travel rule
Meet the virtual-asset service-provider duties, including the FINMA travel-rule expectation for transfers.
VASP & travel ruleOngoing
Outsourced AML officer
A qualified responsible officer, onboarding, monitoring and reporting run for you from day one.
Outsourced AML officerIssuance
Stablecoin issuance
Structure a Swiss stablecoin against the banking-law and deposit-protection questions it raises.
Stablecoin issuancePerimeter
SRO membership
Affiliate with a self-regulatory organisation where your activity makes you a financial intermediary.
SRO membershipScale-up
Banking & fintech licence
Move from the fintech sandbox to a fintech or banking licence as deposits and balances grow.
Banking & fintech licenceFoundation
Swiss company formation
Incorporate the operating entity with the substance a regulator and a bank will expect.
Swiss company formation Talk to the desk
Speak to a partner who knows the sector
No intake form to a junior, no call centre. The partner who reads your enquiry is the one who has run this structure before, and the one who will own your file. Outline your situation and you will have a considered reply, with the likely route and the next step, within one business day.
Why Goldblum and Partners
Swiss depth, one accountable partner
Crypto rarely fits the template, and Swiss precedent is still forming. We have specialised in FINMA and SRO work since 2014, the firm has been independent since 2007, and Goldblum and Partners has been ranked by IFLR1000 across editions from 2015 to 2026. One partner owns your file across token ruling, licence and AML, so the regulatory story stays coherent from the first conversation to the bank account.
FAQ
Frequently asked questions.
01Which authorisation does a crypto exchange need in Switzerland?
Most spot exchanges and brokerages act as financial intermediaries and need SRO membership (under the Anti-Money Laundering Act), not a full FINMA licence. This requires affiliation with a recognised SRO such as VQF in Zug. If you hold client deposits in a way that creates a claim, or run a trading venue for tokenised securities, you cross into FINMA licensing territory instead.
02What's the difference between SRO membership and a FINMA licence?
SRO membership is an anti-money-laundering affiliation under the Anti-Money Laundering Act; it covers AML duties only. A FINMA licence is a prudential authorisation to carry on regulated activities (banking, fund management, securities dealing). Many crypto businesses need only SRO membership; those touching deposits or securities need a full FINMA licence instead. Some need both.
03When can a token issuer launch without a FINMA licence?
A pure payment-token issuance engages anti-money-laundering rules, where SRO membership is relevant if the issuer acts as an intermediary. But an asset token is treated as a security (needs prospectus and securities law), and a utility token's classification turns on its features. The right first step for any issuer is a FINMA token classification ruling, which settles the category before the token generation event.
04What is a DLT trading facility licence?
A DLT trading facility licence is a full FINMA authorisation for running multilateral trading in tokenised securities or digital assets. It sits outside the SRO route. This is not an SRO matter; it requires separate FINMA authorisation and engages securities and venue rules, making it heavier and more complex than a spot exchange under SRO membership.
05Does a stablecoin issuer need a banking licence?
A redeemable stablecoin backed by fiat usually creates a claim that looks like a deposit, which engages banking or fund rules depending on the reserve structure. SRO membership alone does not cover it. Today the analysis turns on whether the reserve structure and redemption mechanics create a deposit claim; the answer determines whether banking or fintech licensing applies.
06How long does it take to get SRO membership?
Typically two to four months from a complete SRO application, driven less by the SRO's processing time than by how ready the business is: its AML framework, KYC procedures, monitoring tooling, fit-and-proper evidence on people, and Swiss operating substance. A weak or generic AML file is the usual cause of delay. FINMA licensing takes considerably longer.
07What does an outsourced AML officer do?
An external AML Officer (MLRO) serves as your designated compliance officer, handling red-flag escalation, the SAR/MROS reporting process, and board-level reporting on anti-money-laundering matters. They also coordinate periodic audits, maintain the compliance framework, oversee KYC onboarding and transaction monitoring, and manage regulatory correspondence. An outsourced officer is accepted by SROs and FINMA as an alternative to an in-house function.
08What minimum Swiss substance does a crypto business need?
SRO membership and FINMA licensing attach to a Swiss entity with real substance: a Swiss AG or GmbH, a registered office, resident director, and genuine operating presence. A foreign company cannot 'get a Swiss licence' without Swiss presence. Minimum set-up includes a Swiss board, an AML Manager, an external auditor, and visible operational presence (office, website, landline).
09What does it cost to run a licensed crypto firm in Switzerland?
First-year all-in costs for an SRO-route firm typically run CHF 50,000–150,000 (entity setup, AML framework, admission, first audit, advisory combined). VQF charges an admission fee of about CHF 1,800 and a minimum annual fee around CHF 1,250. Share capital requires CHF 100,000 for an AG or CHF 20,000 for a GmbH. A FINMA licence carries materially higher costs.
10Can I get a Swiss crypto licence as a foreign company?
No. A Swiss authorisation (SRO membership or FINMA licence) attaches to a Swiss legal entity with real presence: an office, qualified people and genuine operating substance. A foreign company cannot obtain Swiss regulatory approval without Swiss presence. We form the entity, arrange the substance and open banking as part of the same project, so the authorisation rests on a properly constituted Swiss entity.
The client's stories
What clients say
Rated 5.0 / 5 from 38 reviews on Google. Read them on Google →
“Perfekter Service! Wir wollten eine AG in der Schweiz übernehmen und hatten kaum Zeit – innerhalb weniger Tage war alles organisiert, inklusive Notar, Handelsregister und Bank.”
“We consulted Goldblum and Partners for structuring our crypto project under Swiss law. Their team was clear about the threshold between non-custodial and financial-intermediary status.”
“Équipe sérieuse. La documentation AML fournie était claire et adaptée à notre activité crypto. Je recommande.”
“Professionisti veri. Conoscono bene la legge svizzera e si sono occupati di ogni aspetto del passaggio azionario.”
Launching a crypto or fintech model in Switzerland?
Tell us what your token does and how clients use it. A partner will name the classification, the licence route and the AML setup it needs — and reply within one business day.
