Practitioner's note: onboarding a crypto company at a Swiss bank

Read the PDF edition (1 page)

A Swiss bank that onboards a crypto company today works through a set of questions that has become fairly standard. It identifies the beneficial owners and controlling persons in the ordinary way. It then examines the source of the company's funds and wealth, which for a crypto company often means the proceeds of a token sale or of trading in crypto-assets. It requires evidence of the flows on the blockchain, often supported by a report from an analytics provider. It asks whether the company is itself a financial intermediary, and if so, whether it is affiliated to a self-regulatory organisation or holds a FINMA licence. It checks the token's classification and any legal opinion or FINMA no-action letter. Finally, it assesses the company's exposure to sanctioned persons and jurisdictions, which since 2022 has included an examination of links to Russia (see Part I).

The adviser who prepares a crypto client for this process can save time by assembling a file in advance: the corporate documents, the register of beneficial owners, the white paper and terms of the token sale, the legal opinion, the analytics report on the relevant wallets, the SRO membership or licence as well as the audited accounts where they exist. The file will not guarantee acceptance, because banks remain selective and several still refuse crypto clients as a matter of policy. It will, however, shorten the discussion and reduce the risk of rejection on formal grounds.

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.

English

Contact

Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

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.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

Get in touch →

Practitioner's note: onboarding a crypto company at a Swiss bank

Setting up or expanding in Switzerland?