Zug in the regulatory competition

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The regulatory framework is one of the main factors in the international competition between crypto hubs. As an early mover, Switzerland gained a lead over most other jurisdictions through FINMA's guidelines of 2018 and the DLT Act of 2020. That lead has narrowed since the European Union adopted MiCA. Singapore, Hong Kong, Dubai and Abu Dhabi have created licensing regimes for crypto service providers, while the United Kingdom is building its own regime.¹ The United States has changed its approach in 2025 with a law on stablecoins and a more favourable attitude of its regulators.²

Switzerland retains several advantages. Its framework is stable and technology-neutral, administered by a regulator with experience of crypto-assets since 2014. Its private law recognises ledger-based securities and protects clients in the bankruptcy of custodians. Its courts and professional services are reliable. Its disadvantages are the absence of access to the European market, the uncertainty of case-by-case classification and the gaps that the current reform is intended to close. For Zug, the question is whether the Swiss framework can keep pace with its competitors while preserving the qualities that attracted the industry in the first place. Part K returns to that question.

Notes

Singapore: licences for digital payment token services under the Payment Services Act 2019 (MAS, reply to parliamentary question, 26 July 2021, mas.gov.sg) and FSMA 2022 Part 9 in operation from 30 June 2025 (Allen & Gledhill, 10 June 2025, allenandgledhill.com); Abu Dhabi: ADGM, "ADGM launches crypto asset regulatory framework", 25 June 2018, adgm.com; Hong Kong VATP licensing regime in force since 1 June 2023 (Davis Polk, 20 June 2023, davispolk.com); Dubai VARA established 2022 (vara.ae); UK regime under FSMA, draft SI published 29 April 2025 and laid in December 2025 (gov.uk), see the footnotes below. ↩
The White House, fact sheet "President Donald J. Trump Signs GENIUS Act into Law", 18 July 2025, whitehouse.gov; SEC press release 2025-30 of 21 January 2025 (Crypto Task Force) and 2025-47 of 27 February 2025 (dismissal of the enforcement action against Coinbase), sec.gov. ↩

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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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.

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Zug in the regulatory competition

Notes

Setting up or expanding in Switzerland?