Swiss SRO Membership for Crypto Businesses

Is This the Right Fit?

May fit: payment businesses, money exchangers and crypto businesses handling client assets professionally in Switzerland.

Separate route: businesses seeking banking, securities or portfolio-management permissions.

Needs assessment: a fintech company providing software without asset control, or operating across borders. Functions, professional activity and Swiss connections determine applicability.

Which Regulatory Route Applies?

The authorization categories distinguish membership from a license in Switzerland. A FINMA inquiry can clarify uncertain boundaries.

Which Activities Need Assessment?

Payments
Transfers, payment instruments and payment systems involving client funds. Deposit-taking and infrastructure permissions require separate checks.

Exchange
Money exchange and virtual currency trading. Securities-related products need additional analysis.

Wallets
Custody or control of client assets. Asset allocation and deposit treatment can change the route.

Other intermediation
Fiduciary transactions, credit and leasing. Trustee authorization and consumer-credit requirements must be checked separately.

Under FINMA guidance, actual services determine coverage. Tokenization alone does not establish eligibility: payment, exchange and custody functions matter.

What Will Gofaizen & Sherle Handle?

• Assess the business model and prepare the regulatory business case.
• Support Swiss company setup, local director and AML officer recruitment, and office arrangements.
• Prepare AML/KYC policies and coordinate the membership application and responses.
• Assess banks and electronic money institutions (EMIs) and support account applications.

Clients provide accurate ownership, management and financial information and implement controls. The SRO decides admission, auditors assess compliance, and banks decide onboarding.

What Does the Scope Include?

Budget for professional fees, membership fees, audit costs and ongoing compliance support. Confirm inclusions in the agreed scope. Company capital is not a service fee.

What Do We Need From You?

• Personal documents: passports, CVs, criminal record certificates and personal declarations.
• A brief description of the company’s business model (1–2 A4 pages).
• Preferred company name.
• Proof of residential address for all directors and shareholders, such as a utility bill.
• Power of attorney.
• Company organizational chart.
• Extract from the Commercial Register.
• Annual accounts: balance sheet, profit and loss statement, and notes.
• Confirmation of the external auditor’s appointment.

What Determines the Timeline?

Preparation: company formation, governance and document completeness.

Review: selected organization's procedure, model complexity and clarification rounds.

Operational setup: banking can proceed in parallel, with separate approval dependencies.

The SRO application timeline is assessed after reviewing these inputs.

How Does the AMLA Framework Work?

Under AMLA Article 2(3) and AMLA Article 14(1), covered professional financial intermediaries must affiliate with a recognized SRO. The Anti-Money Laundering Ordinance (AMLO) helps determine professional activity.

FINMA recognizes and supervises these self-regulatory organizations. The member's SRO supervises anti-money laundering and counter-terrorist financing (AML/CFT) compliance, including due diligence. Membership does not confer general FINMA authorization.

What Is the Current Regulatory Status?

The reform introduces a beneficial-ownership register and duties for certain advisory activities. Specific application rules must be checked when selecting the SRO.

Company domicile also affects commercial registration, local arrangements and cantonal requirements. Work/residence permissions need separate assessment.

What Continues After Admission?

Client checks
Compliance staff identify customers and beneficial owners, assign risk ratings at onboarding and update retained KYC files when required.

Monitoring
Operations monitor transactions throughout the relationship and document unusual activity. The responsible function records escalation decisions and reports qualifying suspicions to MROS, Switzerland's money-laundering reporting office.

Governance
Management maintains directives, training records and audit evidence. Annual declarations where required, audit frequency and material-change notifications follow applicable law and the organization's rules.

What Are the Regulatory Risks?

Penalties and suspension depend on the applicable rules and breach.

How Does Banking Work?

Account onboarding runs separately. Affiliation replaces neither Swiss banking/FinTech authorization nor applicable foreign payment-institution/EMI or payment-system permissions.

Which Taxes Need Review?

Swiss corporate tax includes federal, cantonal and communal layers. Canton, entity and payment/crypto flows determine treatment. Assess VAT, withholding tax and stamp duties separately, plus transfer pricing for cross-border group transactions. Membership itself creates no tax exemption.

When Should You Consider Another Route?