Swiss AML Rules for Crypto: 2026 Update

Introduction to Swiss AML for Digital Assets

Switzerland’s anti-money laundering framework, anchored in the Anti-Money Laundering Act (Geldwäschereigesetz, AMLA) and its implementing ordinances, applies comprehensive due diligence, monitoring, and reporting obligations to financial intermediaries engaged in crypto and distributed ledger technology activities. As of 2026, Switzerland’s AML framework for digital assets reflects progressive alignment with Financial Action Task Force (FATF) standards, domestic legislative refinements, and evolving supervisory expectations from FINMA and the self-regulatory organisations (SROs) responsible for front-line AML supervision.

The Confederation’s approach to crypto AML is characterised by technology neutrality — applying the same substantive obligations to DLT-based transactions as to traditional financial services — whilst acknowledging the operational specificities of blockchain-based transfers through targeted implementation guidance.

Financial Intermediary Status

Scope of Application

The AMLA applies to financial intermediaries, defined broadly to include persons who on a professional basis accept, hold, or help to transfer or invest assets belonging to others. In the DLT context, the following activities typically trigger financial intermediary status:

• Cryptocurrency exchange services: Converting between fiat currencies and cryptocurrencies, or between different cryptocurrencies
• Custodial wallet services: Holding private keys or otherwise controlling digital assets on behalf of clients
• Token issuance and distribution: Issuing or distributing payment tokens or asset tokens to the public
• DLT trading facility operation: Operating platforms for the trading of DLT-based securities under a DLT trading facility licence
• Payment services: Processing payments using distributed ledger technology

SRO Affiliation

Financial intermediaries that are not directly supervised by FINMA must affiliate with a recognised self-regulatory organisation for AML compliance purposes. Several Swiss SROs have developed specific guidelines for DLT-related members, addressing the application of customer due diligence, transaction monitoring, and record-keeping obligations to blockchain-based activities.

FINMA-supervised institutions — including banks, securities firms, and fintech licence holders — are subject to direct FINMA AML supervision under the AMLA and the FINMA Anti-Money Laundering Ordinance (AMLO-FINMA).

Customer Due Diligence

Identification and Verification

Swiss AML rules require financial intermediaries to identify and verify the identity of contracting parties and beneficial owners before establishing a business relationship or executing occasional transactions above defined thresholds. For DLT-related business relationships, the identification process must address the specific challenges of digital-native onboarding, including:

• Remote identification: FINMA has permitted video and online identification procedures, subject to defined security and verification standards. DLT service providers may utilise digital identity verification solutions, provided they achieve a level of assurance equivalent to face-to-face identification.
• Wallet attribution: Where a client presents a self-custodied wallet address as part of the onboarding process, the intermediary must verify the client’s control over the wallet through cryptographic proof (such as message signing) and assess the wallet’s transaction history for AML risk indicators.
• Beneficial ownership: The identification of beneficial owners applies to DLT-related business relationships in the same manner as traditional financial services. For corporate clients, this includes identifying natural persons who ultimately control the entity, whether through shareholding, voting rights, or other means of influence.

Enhanced Due Diligence

Enhanced due diligence (EDD) is required for business relationships presenting elevated money laundering or terrorist financing risks. In the DLT context, risk indicators triggering EDD may include:

• Transactions involving privacy-preserving DLT technologies or privacy coins
• Business relationships with clients domiciled in high-risk jurisdictions
• Complex transaction patterns involving multiple intermediaries, mixers, or tumbling services
• Significant transactions involving unhosted or self-custodied wallets without clear provenance
• Exposure to darknet markets, sanctioned addresses, or flagged entities

The Travel Rule

Swiss Implementation

Switzerland has implemented the FATF travel rule (Recommendation 16) for virtual asset transfers, requiring originator and beneficiary information to accompany cryptocurrency transfers between financial intermediaries. The Swiss implementation, codified in FINMA’s revised AMLO-FINMA and the SRO regulations, requires the following information to be transmitted with qualifying transfers:

Originator information: Name, account number (or wallet address), address (or national identity number, customer identification number, or date and place of birth)

Beneficiary information: Name and account number (or wallet address)

Practical Implementation Challenges

The travel rule presents significant implementation challenges for DLT-based transfers, as public blockchain protocols do not natively support the transmission of counterparty information alongside value transfers. Swiss financial intermediaries have adopted various technical solutions to address this challenge:

• TRUST protocol: Participation in the Travel Rule Universal Solution Technology consortium for standardised counterparty data exchange
• OpenVASP: Utilisation of the open-source Virtual Asset Service Provider messaging protocol
• Bilateral solutions: Direct integration between compliant intermediaries for travel rule data exchange

For transfers to or from unhosted wallets — where no counterparty financial intermediary exists — Swiss AML guidance requires the originating intermediary to collect beneficiary information from the client and conduct appropriate risk assessment before processing the transfer.

Thresholds

The travel rule applies to all transfers between financial intermediaries without a de minimis threshold under Swiss law, aligning with FATF’s recommendation for comprehensive travel rule coverage. For occasional transactions involving non-established clients, the identification threshold of CHF 1,000 applies, above which full customer identification and travel rule compliance are required.

Transaction Monitoring

Ongoing Monitoring Obligations

Financial intermediaries must implement ongoing transaction monitoring systems capable of detecting unusual or suspicious activity in DLT-based transactions. Monitoring parameters should be calibrated to the specific risk profile of DLT activities, incorporating:

• On-chain analytics: Blockchain analysis tools that identify transaction patterns, counterparty risk scores, and exposure to flagged addresses
• Behavioural analytics: Monitoring for deviations from established client transaction patterns, including unusual volumes, frequencies, or counterparty profiles
• Cross-referencing: Integration of on-chain monitoring with traditional AML screening, including sanctions lists, politically exposed person databases, and adverse media monitoring

Suspicious Activity Reporting

Where monitoring identifies transactions or business relationships that give rise to a suspicion of money laundering, terrorist financing, or criminal origin of assets, the financial intermediary must file a suspicious activity report (SAR) with the Money Laundering Reporting Office Switzerland (MROS). The reporting obligation is triggered by a reasonable suspicion, not by certainty, and the intermediary must refrain from tipping off the client about the report.

MROS has reported a steady increase in SARs relating to cryptocurrency and DLT-related activities, reflecting both the growth of the sector and the maturation of monitoring capabilities among Swiss financial intermediaries.

DeFi and AML

Regulatory Perimeter

The application of AML obligations to decentralised finance protocols remains one of the most complex questions in Swiss DLT regulation. FINMA has indicated that where identifiable persons or entities exercise control over DeFi protocol operations — including governance, parameter setting, or fund management — those persons or entities may qualify as financial intermediaries subject to AML obligations.

Pure smart contract interactions without identifiable intermediaries present a regulatory gap that Switzerland, alongside other jurisdictions, is actively seeking to address. The FATF’s updated guidance on virtual assets and virtual asset service providers has expanded the scope of AML obligations to include certain DeFi participants, though the practical implementation of these requirements in truly decentralised environments remains challenging.

FATF Alignment and Mutual Evaluation

Switzerland’s crypto AML framework has been assessed positively in FATF mutual evaluations, with the evaluators recognising the Confederation’s comprehensive application of AML standards to virtual asset activities. Areas identified for continued development include the consistency of SRO supervision across DLT-related members, the effectiveness of travel rule implementation for cross-border transfers, and the adequacy of resources allocated to cryptocurrency-related financial intelligence at MROS.

Outlook

Swiss AML regulation for crypto and DLT activities continues to evolve, driven by FATF standard-setting, domestic legislative review, and practical supervisory experience. Key developments anticipated in 2026 and beyond include potential revision of the AMLA to address DeFi-specific obligations, refinement of travel rule implementation standards for emerging transfer protocols, and enhanced cooperation between Swiss AML authorities and international counterparts on cross-border digital asset investigations.

The integration of advanced blockchain analytics, artificial intelligence-driven monitoring capabilities, and DLT identity solutions into the Swiss AML compliance framework is expected to enhance both the effectiveness and efficiency of anti-money laundering controls across the DLT sector.

Donovan Vanderbilt is a contributing editor at ZUG DLT. This article is informational and does not constitute legal or financial advice.