Lugano's market and a practitioner's checklist

Providers in Ticino

Lugano's market for Kryptowerte und Digital Assets consists of three groups. The first comprises the specialized banks and brokers from other parts of Switzerland that have opened offices in the city since Plan ₿. Sygnum opened its Lugano office in March 2025. Bitcoin Suisse, founded in 2013 in Zug and employing more than two hundred people, opened an office in the Dagorà innovation hub in Lugano in September 2025. Its chief executive officer Peter Camenzind described the move as a sign of confidence in the potential of the region. In March 2025 Bitcoin Suisse had entered a partnership with SwissLedger, an initiative of the City of Lugano that promotes the use of Bitcoin and other Kryptowerte und Digital Assets.¹ The second group consists of the local banks and asset managers that have added the asset class to their offer, with BancaStato as the most visible example since July 2026 and a number of independent asset managers who invest client portfolios partly in bitcoin through Swiss custodian banks. The third group consists of start-ups, developers and service companies attracted by Plan ₿ and by the city's events, which Chapter I.I describes, and by the research institutions treated in Chapter I.III.

The legal environment of all three groups is federal. FINMA in Bern supervises the banks, securities firms and FinIA institutions. The self-regulatory organizations, wherever they are based, supervise the other financial intermediaries. The Office of the Attorney General of Switzerland and the Federal Criminal Court in Bellinzona deal with large fraud and money laundering cases, including those involving Kryptowerte und Digital Assets, while the Ticino Public Prosecutor's Office handles cases within cantonal jurisdiction. Local voices have described the opportunities and the risks of this environment. When the city launched its plan in March 2022, Alessandro Trivilini, head of the forensic IT service at the University of Applied Sciences and Arts of Southern Switzerland (SUPSI), warned that the main risks lay in the criminal exploitation of regulatory gaps. Luca Soncini of the Università della Svizzera italiana (USI) observed that traditional banks saw potential in the field and preferred investing or partnering to being left isolated.²

Launching a token from Lugano

The following checklist summarizes the legal steps that a Lugano issuer must take under current law. It does not replace a legal opinion on the specific project.

For the practitioner. Launching a token from Lugano:

• Classify the token according to the FINMA guidelines (payment, utility, asset or hybrid) and determine whether it is a security under Art. 3 lit. b FinSA and a financial instrument under Art. 3 lit. a FinSA.
• Choose the issuing entity: a Ticino società anonima, a foundation or, for tokenized shares, the company itself issuing ledger-based securities under Art. 622 para. 1 and Arts. 973d ff. CO with a registration agreement.
• Examine the banking perimeter: does the issuer accept funds with a repayment obligation (Art. 1 para. 2 BankA), and does a stablecoin structure meet FINMA Guidance 06/2024?
• Prepare the offering documents: a FinSA prospectus for securities offered to the public, or reliance on an exemption; a MiCAR white paper if the token is to be offered to the public in Italy or elsewhere in the European Union.
• Settle the anti-money laundering position: affiliation with a self-regulatory organization for the issue of payment tokens, identification of buyers and travel rule procedures.
• Organize custody: who holds the keys, and are client tokens segregable under Art. 242a DEBA?
• Obtain tax rulings from the Ticino Divisione delle contribuzioni and, for withholding tax and stamp duties, from the ESTV.
• Register beneficial owners in the federal transparency register and keep the share register current (Chapter G.IV).
• Define the Italian marketing strategy under Art. 61 MiCAR and the Italian decree of 2024, and avoid any solicitation without authorization.
• Seek FINMA's assessment for doubtful classifications before the launch.

Notes

1. "Bitcoin Suisse punta sul Ticino: nuovo ufficio a Lugano", finews.ch, 15 September 2025, https://www.finews.ch/ticino/69405-bitcoin-suisse-punta-sul-ticino-nuovo-ufficio-a-lugano (Dagorà Lifestyle Innovation Hub; founded 2013; more than 200 employees; partnership with SwissLedger, an initiative of the City of Lugano, in March 2025; Peter Camenzind: "La nostra presenza a Lugano è molto più di un semplice nuovo ufficio"). On Sygnum see finews.ch, 16 March 2025 (above). ↩
2. "Lugano punta alle criptovalute tra rischi e opportunità", blue News, 4 March 2022, https://www.bluewin.ch/it/attualita/regionali/lugano-punta-alle-criptovalute-tra-rischi-e-opportunita-1119598.html (statements of Alessandro Trivilini, SUPSI, and Luca Soncini, USI). ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.