Regulation on Zug Notes

Two New FINMA License Categories Proposed: What the Crypto-Institution License Means in Practice

Tue, 10 Mar 2026 00:00:00 +0000

📅 Field note from: March 2026 | Last updated: May 2026 Written shortly after FINMA published the consultation paper; updated with consultation progress observations in May 2026.

On October 22, 2025, the Swiss Federal Council released a draft amendment to the Financial Institutions Act — FinIA — and opened a public consultation. The document proposes two new license categories: the crypto-institution (Krypto-Institut) and the payment instrument institution (Zahlungsmittelinstitut). The consultation period closed on February 6, 2026.

FINMA's Crypto Guidance 01/2026: What It Actually Means for Custody (Not the Legal Version)

Sat, 14 Feb 2026 00:00:00 +0000

On January 12, 2026, FINMA published Guidance 01/2026 — its clearest statement yet on how Swiss regulated institutions must handle crypto-asset custody. The document is dense, technically precise, and written for compliance officers, not individual holders.

This is an attempt to translate what it actually says, what it changes in practice, and where it leaves open questions that still matter if you hold crypto in Switzerland.

Why FINMA Published This Now

The timing is not accidental. Three things converged at the start of 2026.

Switzerland's CARF Delay Explained: What 2027 Really Means for Crypto Holders Here

Thu, 08 Jan 2026 00:00:00 +0000

The announcement came on January 2, 2026 — two days into the year CARF was supposed to go live. Switzerland’s Federal Council confirmed that the Crypto-Asset Reporting Framework had been enacted into Swiss law as planned, but that actual data exchange with foreign tax authorities would not happen until at least 2027.

The headline spread fast. “Switzerland delays crypto tax sharing” was the framing most outlets used, and it was accurate enough to quote. But the implications for people who actually hold crypto here are more layered than that framing suggests.

Does MiCA Apply in Switzerland? A Field Note on the Border

Mon, 22 Sep 2025 00:00:00 +0000

📅 Field note from: September 2025 | Last updated: June 2026

No. MiCA does not directly apply in Switzerland, because Switzerland is not a member of the EU or the European Economic Area, and MiCA is EU law that binds entities inside that bloc. If you are a Swiss resident holding crypto in a Swiss wallet through a Swiss-licensed provider, you sit under FINMA’s framework — not MiCA’s. That is the clean answer to the question most people are actually searching for.

MiCA vs FINMA: A Field Note from Someone Who Watches Both

Fri, 18 Jul 2025 00:00:00 +0000

Most regulatory comparisons frame MiCA and FINMA as competitors — two jurisdictions fighting over the same pool of crypto businesses. That framing is wrong, and it gets more wrong the closer you sit to the Swiss-EU border.

I am writing this from Zug. Two of the companies I follow closely have EU clients. One has a Swiss banking license. The practical question they are asking right now is not “MiCA or FINMA?” It is “How do these two frameworks interact when your customers are in Frankfurt but your custody infrastructure is in Zurich?”

Switzerland After FTX: How FINMA Responded and What It Changed

Thu, 12 Jan 2023 00:00:00 +0000

📅 Field note from: January 2023 | Last updated: May 2026 Originally written two months after the FTX collapse from inside Zug; updated with three years of regulatory follow-on observations in May 2026.

November 11, 2022 was a Friday. FTX had filed for Chapter 11 bankruptcy the day before. Sam Bankman-Fried had resigned. Eleven billion dollars in customer funds had vanished.

I remember checking Telegram channels that morning. There was the usual noise — speculation about contagion, lists of which platforms had exposure to FTX or Alameda Research, arguments about whether this was the end of crypto or just another cycle bottom. What struck me, working out of Zug, was a different question: what was FINMA going to do?

The DLT Act Explained Without a Law Degree: What Changed for Crypto in Switzerland

Mon, 01 Feb 2021 00:00:00 +0000

📅 Field note from: February 2021 | Last updated: May 2026 Originally written shortly after the DLT Act came into force; updated with five years of practical observations in May 2026.

February 1, 2021 is a date that most crypto holders outside Switzerland have never heard of. Inside Zug, the people who cared about it were a specific type: lawyers at firms specialising in digital assets, compliance officers at custody providers, and the handful of startups that had been waiting for this exact legislation before they could build certain products.

When FINMA Gave Crypto Its First Banking Licenses: A 2019 Field Report

Wed, 04 Sep 2019 00:00:00 +0000

📅 Field note from: September 2019 | Last updated: May 2026 Originally written shortly after the FINMA announcement; updated with current SEBA/Sygnum status in May 2026.

August 26, 2019 was not a day that made headlines outside of crypto circles. But in Zug, people who had been watching FINMA’s posture toward blockchain companies for the previous five years understood that something significant had just happened.

FINMA had granted banking and securities dealer licences to two firms — SEBA Crypto AG and Sygnum — describing them in the official press release as the first “pure-play blockchain service providers” to receive this authorisation in Switzerland. The phrase “pure-play” was deliberate. Traditional Swiss banks had been experimenting with digital asset services for years. What was new was a bank built entirely around crypto, licensed to operate on the same regulatory footing as the institutions it was meant to replace.

FINMA's ICO Guidelines in 2018: What They Revealed About Switzerland's Regulatory Philosophy

Sun, 18 Feb 2018 00:00:00 +0000

📅 Field note from: February 2018 | Last updated: May 2026 Originally written days after FINMA published the ICO Guidelines from inside Zug; updated with eight years of regulatory follow-on observations in May 2026.

February 16, 2018 was not a day that produced a press conference or a major announcement event. FINMA published its ICO guidelines on a Friday, in German and English, six pages long. They went up on the FINMA website with the usual restrained formatting of Swiss regulatory communications.