Exhanges and trading platforms for cryptocurrencies may be considered a financial service provider. Resulting duties include, for instance, duty to provide information to clients as well as prospectus and licensing requirements according to the Financial Services Act.
Execution-only exemption: If client orders are only executed or forwarded (no advisory or similar services provided), the financial service provider is exempt from the duty to supply a Key Information Document (KID) or the duty to check suitability and appropriateness.
Note: Exchange and trading platforms for security tokens are considered a trading venue subject to the Financial Market Infrastructure Act (FinMIA) and require a FINMA license.