Foundations and anti-money-laundering compliance

A crypto foundation that receives contributions in crypto-assets, pays grants in crypto-assets or holds them for others may have obligations under the Anti-Money Laundering Act. Even where the foundation is not itself a financial intermediary, its bank will require it to know the origin of its assets and the identity of the recipients of its payments. The foundation must therefore build compliance procedures that are proportionate to its activities, identifying major donors and grant recipients, screening them against sanctions lists and documenting the purpose of each payment.

The expectations of banks and supervisors have risen over time, so that a foundation that was set up in 2014 with minimal procedures would today face detailed questions from its bank. Many foundations have hired compliance officers and engaged external providers for the screening of transactions on the blockchain. The costs of compliance have become a significant part of their budgets, contributing to the concentration of the industry in larger and better-resourced organisations.

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 September 2025.

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I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

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