Stay compliant with Swiss AML regulations and conduct various financial services without direct FINMA supervision.
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Why Switzerland
01
Global gateway to financial markets
02
Pragmatic, technology-neutral regulations
03
No MiCA exposure – independent legal regime
04
Stable, respected legal environment with crypto-friendly banks
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Home to “Crypto Valley”
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Reduced regulatory friction between Switzerland and the UK
What is SRO?
Self-Regulatory Organization (SRO) is an officially recognised organisation authorised by the Swiss Financial Market Supervisory Authority (FINMA) to supervise affiliated financial intermediaries regarding compliance with Swiss AML/CTF regulations.
01
A recognised legal status under the Swiss Anti-Money Laundering Act (AML Act)
02
Enables certain crypto services without requiring a full banking or fintech license
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Designed for financial intermediaries subject to AML regulation
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Fast-tracks operations as a Virtual Asset Service Provider (VASP)
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Allows capital injection in cryptocurrencies
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Flexible and cost-efficient alternative to full licensing, ideal for startups and smaller financial institutions
What SROs can do
By becoming an SRO, your company can comply with Swiss AML/CTF regulations without requiring direct supervision by FINMA, Switzerland’s central financial regulator.
01
Payment Services
Fiat & Crypto Payments: Facilitating and processing payment transactions in both traditional currencies and cryptocurrencies
Fund Transfers: Transferring funds and crypto assets
Third-Party Asset Transfers: Accepting or assisting in the transfer of assets belonging to others
Electronic Transfers: Providing electronic payment services
02
Crypto-Specific Services
Crypto Custody: Offering segregated wallet services for unlimited crypto assets
ICO/STO/ISPO: Launching Initial Coin Offerings, Security Token Offerings, or Initial Staking Offerings
Staking: Providing staking services for crypto assets
03
Other Financial Services
Card Issuance: Managing or issuing payment instruments, including credit and debit cards
Fiat/Crypto Exchanges (CEX/FX): Operating exchanges for trading fiat and crypto assets (excluding derivatives)
Brokerage/Trading: Trading cryptocurrencies, currencies, precious metals, and commodities
Asset Management: Managing both fiat and crypto assets
Credit & Loan Operations: Providing mortgages, leasing, commercial loans, and consumer credit (some activities may require additional authorisation)
Acceptance of Deposits: Generally permitted to accept deposits up to CHF 1 million; higher amounts may be accepted if held no longer than 60 days, with exceptions for institutional investors
SRO Application Process
1
Defining the business model, including operational and cash flow descriptions
2
Collecting all required information and personal documents for the SRO application
3
Preparing a legal opinion on the business model and AML/CTF compliance policy
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Submitting the application package, all legal, operational, and compliance documentation
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Communicating during the review process, including responding to any questions or document requests
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Training the internal team on technical tools and processes for KYC onboarding and Travel Rule compliance
SRO Membership: Minimal Substance Requirements
Board of directors
At least one member with sole signatory rights must be domiciled in Switzerland
Management
Team with fintech experience covering roles in management, operations, finance, IT, risk management, and compliance.
AML special department
Based in Switzerland. If outsourced – should be supervised by a Swiss Board Member.
Shareholder(s)
At least one shareholder (can be domiciled abroad)
Minimal capital
CHF 20,000 for GmbH or CHF 100,000 for AG, can be injected in cryptocurrency
SRO Membership Timeline
The average expected timeline is approximately 4-6 months, in some cases may take up to 6-9 months.
Business Model Outline
Corporate Bank Account Setup
Company Incorporation
MLRO & Auditor Appointment
Documents Preparation
SRO Application Submission
SRO Evaluation Process
Go-Live: Compliance and IT Setup
How Advapay supports
Advapay provides end-to-end support for obtaining SRO membership tailored to crypto and fintech businesses entering the Swiss market.
01
Company Formation
Strategic selection of legal entity type (AG or GmbH)
Preparation and customisation of incorporation documents
Assistance with opening the initial capital deposit account
Coordination with notaries and Swiss authorities
Completion of Commercial Registry registration
02
Opening Crypto-Friendly Corporate Bank Accounts
Tailored matchmaking with Swiss banks open to crypto businesses
Support in compiling and verifying KYC/AML documentation
Pre-filling of required banking forms
Direct introductions to banking representatives and communication facilitation
Step-by-step support during the onboarding and interview processes
03
SRO Membership Application
Assessing and defining the business model, including operational flow and financial structure
Business plan preparation
Collecting and organising required personal and company documents (e.g., CVs, ID copies, criminal record extracts)
Drafting of a legal opinion covering the business model
Preparing AML/CTF compliance policy
Training the team on KYC procedures, onboarding tools, and Travel Rule requirements
Liaising with the SRO, addressing feedback, and preparing for interviews and final approval
04
Ongoing Compliance and Corporate Services
Continuous administration and compliance for AG/GmbH entities
Provision or coordination of AML Compliance Officers, including deputy appointments
Business address services and assistance with office rentals
Full-service accounting, financial reporting, and bookkeeping
Transaction monitoring and suspicious activity reporting
Customer screening and risk classification in line with AML requirements
Jurisdictions
for crypto business
We support crypto businesses. We help you find the right jurisdiction to launch and scale your crypto venture with confidence.
All fintech jurisdictions
we cover
We have a strong focus on fintech businesses like digital banks, e-wallets, fiat-crypto wallets, e-commerce banking and remittance.
