Switzerland chose integration over a standalone code, and did it before anyone else. The DLT Act, a package of amendments in force since 2021, wove digital assets into existing law: ledger-based securities with full legal effect under the Code of Obligations, a DLT trading facility license for venues combining trading and settlement, and segregation of crypto assets in bankruptcy. FINMA's 2018 token taxonomy (payment, utility, asset) still frames analysis, and its licensing practice has produced crypto-native banks holding full banking licenses alongside securities firms and the fintech-license tier for deposit-like business.
The Zug crypto cluster operates under ordinary financial market law: AML affiliation is mandatory for financial intermediaries, FINMA's 2024 stablecoin guidance requires issuers to either hold a license or obtain bank default guarantees while warning about the risks of the guarantee model, and Switzerland legislated the OECD's Crypto-Asset Reporting Framework with collection beginning in 2026 for exchanges with partner jurisdictions to follow. The result is a jurisdiction with no crypto act to point to and one of the most complete rulebooks in practice.
The instruments
DLT Act (Federal Act on the Adaptation of Federal Law to Developments in DLT)
Amends ten federal statutes: creates uncertificated ledger-based securities, a DLT trading facility authorization under FMIA, and bankruptcy segregation of crypto-based assets held for customers.
FINMA stablecoin guidance
Stablecoin issuers generally accept deposits: they need a banking license or default guarantees from a bank for each holder, with FINMA flagging the guarantee model's risks to holders and to the guaranteeing banks, plus full AML obligations on issuers.
Crypto-Asset Reporting Framework implementation
Implements the OECD CARF standard for automatic exchange of crypto tax information, with Swiss providers collecting data ahead of exchanges with partner jurisdictions.