Executive summary
This page provides an overview of crypto-asset transfer regulation and Travel Rule requirements in Switzerland. It is intended for virtual asset service providers, financial institutions, and compliance teams operating in or interacting with the Swiss market.
Switzerland applies what is commonly referred to as the “Swiss Rule”, a highly conservative implementation of the Travel Rule that has long exceeded minimum international standards. As of 2026, the Swiss regime has further evolved through the integration of the OECD’s Crypto-Asset Reporting Framework (CARF) and updated FINMA guidance on custodial and bankruptcy-remote asset protection.
This content is provided for informational purposes only and does not constitute legal advice.
Regulatory landscape overview
Switzerland is widely regarded as one of the most stringent jurisdictions globally for crypto-asset regulation. Rather than carving out exemptions or phased approaches, Swiss authorities have consistently applied existing financial-intermediary standards to virtual assets.
Key characteristics of the Swiss approach include:
Early application of Travel Rule obligations to blockchain transfers
Elimination of practical exemptions for unhosted wallet transfers
Strong emphasis on customer identification, ownership verification, and traceability
Expansion of reporting obligations beyond AML to include international tax transparency
The framework aligns with Financial Action Task Force (FATF) standards and increasingly incorporates OECD-level reporting expectations.
Supervisory and regulatory authorities
Travel Rule compliance in Switzerland is overseen through a mixed supervisory model:
Swiss Financial Market Supervisory Authority (FINMA): Regulates banks, securities firms, and larger fintech-licensed crypto entities
Self-Regulatory Organisations (SROs): Bodies such as VQF or PolyReg supervise many smaller crypto brokers and service providers under AMLA
Federal Tax Administration (ESTV): Receives crypto-asset reporting under CARF and international tax exchange frameworks
All professional crypto-asset service providers are classified as financial intermediaries for AML purposes.
Travel Rule status in Switzerland
The Travel Rule is fully implemented and strictly enforced under Swiss AML law and FINMA guidance.
Under the Swiss framework:
Travel Rule obligations apply to professional crypto-asset transfers
Transmission of required data is triggered at defined thresholds
Customer identification and ownership verification requirements apply broadly, regardless of transaction value
Switzerland’s implementation is frequently cited as a reference point for other jurisdictions considering stricter controls.
Timeline and key milestones
August 2019: FINMA publishes Guidance 02/2019, applying the Travel Rule to blockchain transfers
February 2021: Entry into force of the DLT Act, strengthening the legal basis for ledger-based assets
January 2026: Implementation of the OECD Crypto-Asset Reporting Framework (CARF)
January 2026: Publication of updated FINMA guidance clarifying custodial risk and bankruptcy protection expectations
Thresholds and scope
Switzerland applies a conservative threshold model combined with broad identification requirements.
Transmission threshold: CHF 1,000 for Travel Rule data exchange between service providers
Identification baseline: Customer identification applies irrespective of transaction value for exchange and brokerage activity
Scope: Any entity professionally transferring or safeguarding virtual currencies qualifies as a financial intermediary
This structure leaves little room for anonymous or lightly supervised activity.
Required data elements (high-level)
For in-scope transfers, Swiss regulations generally require information relating to:
The originator, including identifying details, address, date and place of birth, and nationality
The beneficiary, including identifying details and wallet or account identifiers
Specific data elements are defined in AMLA, FINMA guidance, and applicable self-regulatory rules and must be made available to authorities upon request.
Local nuances and interpretive considerations
Several features of the Swiss framework are particularly relevant for compliance teams:
Nationality requirement: Swiss rules require the collection of nationality for Travel Rule purposes
Tax transparency: CARF introduces parallel reporting obligations beyond AML
Custody expectations: Updated guidance emphasises segregation, bankruptcy remoteness, and equivalency of foreign custody arrangements
These elements significantly increase operational and compliance complexity.
Self-custodied (unhosted) wallet considerations
Switzerland applies the strictest known approach to transfers involving self-custodied wallets.
Transfers are generally permitted only where ownership or control of the wallet has been verified
Verification is expected to rely on technical or cryptographic proof mechanisms
Transfers involving third-party unhosted wallets face significant restrictions
This effectively closes the “unhosted wallet loophole” present in many other jurisdictions.
Cross-border and interoperability considerations
Switzerland’s high standards create interoperability challenges with less stringent jurisdictions.
Key considerations include:
Enrichment of inbound data received from jurisdictions with higher thresholds
Assessment of equivalency and bankruptcy protection for foreign custody partners
Potential capital or structural implications where foreign protections fall short of Swiss standards
Internationally active firms must account for these asymmetries when operating in or with Switzerland.
Indicative compliance readiness checklist
The following considerations are illustrative and non-exhaustive:
Appropriate FINMA authorisation or SRO affiliation
Ability to apply CHF-based Travel Rule thresholds
Technical capability to verify ownership of self-custodied wallets
Integration of CARF-related data collection and reporting
Record-keeping aligned with Swiss AML and commercial law retention periods