- Direct exchange of cryptocurrency for fiat or other cryptocurrency is subject to AMLA (Supervision and AML)
- For spot transactions, duty to identify clients from CHF 5,000 in currency trading
- Exchanges must take appropriate measures to ensure the client is the owner of the wallet
- Banking/FinTech license is generally not required, unless currency from clients is accepted on a commercial basis and kept in own accounts
- Cryptocurrency exchanges that maintain accounts for investment in various currencies for their clients are not covered by the settlement accounts exemption from deposits under the Banking Act
