Switzerland's crypto travel rule, and the proof it demands

Regulatory analysis · Switzerland

This dossier is about the travel ruleThe requirement that sender and recipient identity data accompany crypto transfers between providers (FATF Recommendation 16). — the requirement that identifying information travels with a payment — and specifically about how Switzerland applies it to transfers of crypto. Switzerland applies it more strictly than any other jurisdiction, and the practical shape of that strictness is easiest to see through a transaction.

Suppose you hold an account with a Swiss crypto institution and you want to send coins to a friend's private wallet. In the EU or the UK that transfer will ordinarily proceed. In Switzerland it will ordinarily be refused, unless the institution has first identified your friend, established who ultimately owns the assets behind the wallet, and satisfied itself by technical means that your friend genuinely controls the address you are sending to. Put plainly: before it will release your coins to someone who is not its customer, the Swiss institution must do to that person substantially what it did to you when you opened your account.

That requirement was set out by FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. in a three-page notice, Guidance 02/2019 of 26 August 2019 — the 02/2019 guidance in what follows. It remains in force and nothing has replaced it.

What the 02/2019 guidance does not do is explain what would count as proof. It requires wallet ownership to be "proven using suitable technical means" and leaves the phrase undefined. The answer to the question every compliance officer actually has — which checks satisfy FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. — has been supplied piecemeal in FINMA's annual reports for 2020 and 2022, and has never been consolidated anywhere.

This dossier therefore does three things. It establishes whether the 02/2019 guidance still stands, and on what evidence. It assembles, for the first time in one table, the six verification methods FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. has said it accepts. And it asks why a requirement of this weight has never been written into the ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. it is read out of, when FINMA revised that ordinance in May 2026 and used the same instrument to codify a different supervisory practice.

In summary

• The requirement. A Swiss institution may transfer crypto to or from an external walletFINMA's term for a wallet held outside the supervised institution — the customer's own, or somebody else's. only where it can establish who controls that wallet. Where the wallet belongs to its own customer, it must prove the customer's control. Where it belongs to anyone else, it must additionally run full customer due diligence on that third party, including beneficial ownership.
• Where it comes from. The 02/2019 guidance, which derives the requirement from Article 10 of FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s Anti-Money Laundering OrdinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. — the provision carrying the travel ruleThe requirement that sender and recipient identity data accompany crypto transfers between providers (FATF Recommendation 16). into Swiss law. Article 10 concerns information accompanying payment orders and does not mention wallets at all.
• Whether it is still current. It is. No later guidance and no circularA FINMA document explaining how it will apply the law. It binds FINMA itself. FINMA says a circular needs no express statutory hook but must trace back to a higher rule. has replaced it, and the ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. beneath it has not been amended since 1 January 2023.
• What is missing from it. The methods that discharge it. Six are recognised; every one of them was announced in an annual report rather than in the guidance, an ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. or a circularA FINMA document explaining how it will apply the law. It binds FINMA itself. FINMA says a circular needs no express statutory hook but must trace back to a higher rule..

What the 02/2019 guidance requires

An external wallet, in FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s usage, is any wallet the supervised institution does not itself control — the customer's own, or a third party's. The question the guidance answers is when a Swiss institution may send coins to one, or accept coins from one.

Its answer, in the guidance itself:

"As long as an institution supervised by FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. is not able to send and receive the information required in payment transactions, such transactions are only permitted from and to external walletsFINMA's term for a wallet held outside the supervised institution — the customer's own, or somebody else's. if these belong to one of the institution's own customers. Their ownership of the external wallet must be proven using suitable technical means."

And where the wallet belongs to somebody else:

"A transfer from or to an external walletFINMA's term for a wallet held outside the supervised institution — the customer's own, or somebody else's. belonging to a third party is only possible if, as for a client relationship, the supervised institution has first verified the identity of the third party, established the identity of the beneficial owner and proven the third party's ownership of the external wallet using suitable technical means."

Three things make this stricter than anywhere else.

1. There is no minimum amount. The duty bites on one franc.
2. The word is proven. Not assessed. Not checked on a risk basis. Proven.
3. A friend's wallet is harder, not easier. Sending to a third party means full customer checks on someone who is not your customer.

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. says outright that this goes beyond the global standard: "Unlike the FATF standards, Article 10 AMLO-FINMA does not provide for any exception for payments involving unregulated wallet providers."

How far beyond the standard — stated precisely

FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s position on transfers to private wallets is set out in its October 2021 guidance on virtual assets, and it is worth quoting because it is often described loosely, including in an earlier version of this dossier.

At paragraph 179 FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. distinguishes three cases: a traditional wire transfer, a transfer between two obliged entities, and "a VA transfer between a VASP and a non-obliged entity (i.e., an unhosted wallet)". Its conclusion is explicit — "The full requirements of Recommendation 16 apply to (a) and (b) but not (c)."

What does apply to (c) is set out at paragraphs 204 and 295. FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. "does not expect that VASPs and FIs, when originating a VA transfer, to submit the required information to individuals who are not obliged entities"; instead the firm "should obtain the required originator and beneficiary information from their customer", because it cannot obtain it from another VASPVirtual-asset service provider — an exchange, custodian or similar business handling crypto for customers.. At 296 it adds that VASPs "should collect data on their unhosted wallet transfers, and monitor and assess that information" against their risk appetite.

And at paragraph 297 FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. lists what a VASPVirtual-asset service provider — an exchange, custodian or similar business handling crypto for customers. may choose to do beyond that. One of the options is "studying the feasibility of accepting transactions only from/to VASPs and other obliged entities, and/or unhosted wallets that the VASP has assessed to be reliable."

Read that sentence next to the Swiss requirement. What FATF offered in 2021 as an option a firm might consider, FINMA had already made compulsory in 2019 — and made compulsory in a stronger form, because FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s word is assessed and FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s is proven.

So the accurate statement of the gap is narrower than "FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. says nothing", and more useful. FATF requires a firm to collect information about the transfer from its own customer, to monitor, and to manage the risk. No FATF instrument requires a firm to establish who controls the receiving address. Switzerland requires exactly that, at any value, and requires full customer due diligence on a third party before it will pay one.

Why it matters

For a firm, this is the provision that stops a payment going out. The clearest way to see the divergence is to run the same instruction through all three regimes: a customer asks to transfer about £2,000 to a wallet belonging to a friend.

For an investigator or a claimant, the same rule reads the other way round. A Swiss firm that may only pay an address it has proved someone controls must be holding, for every address it ever touched: a named and checked customer, the address itself, and a document tying the two together. That is a better attributionA claim about who is behind an address. Never a ledger fact — always cite who made the claim and when. record than the EU or the UK regime produces. The strictest rule creates the best evidence.

Is it still in force? Four checks

A guidance note seven years old, in a field that has changed as fast as this one, cannot simply be assumed to be current — and until 24 August 2026 nobody in this practice had tested the assumption. Three of its own research notes rested on the 02/2019 guidance without asking whether it still stood. Four checks were run, and all four point the same way.

One caution, because it cuts against a quick answer. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s list has no status column. Nothing on it is marked current, revised or withdrawn. The neighbouring archive holds the 64 newsletters FINMA stopped issuing in 2014 — an old format, not a bin for cancelled rules. So being on the list proves FINMA still publishes 02/2019. It does not, by itself, prove the rule still bites.

What proves that is FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. saying so, repeatedly, in its annual reports — and inspecting for it as recently as 2024.

The rule grew, and it grew somewhere odd

Here is the whole life of the rule in one place.

Every addition is in an annual report. An annual report is an account of what a public body did last year. It is not a rule. A firm asking "what must I do?" must read a 2019 notice, then four annual reports, and assemble the answer itself.

The six checks FINMA accepts

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. has never published this table. It is assembled from the 2020 and 2022 reports, and the 2022 report points back to the 2020 one for the earlier entries.

Set that list against the word proven and the distance is plain. A screenshot is a picture. WhitelistingChecking an address once, then trusting it for later transfers without repeating the check. means the check may be years old by the time it matters. The strictest wallet standard in the world is, in its softest corner, a photograph and a promise.

That is not a criticism of the firms. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. allowed the screenshot precisely because the other methods do not work against a pooled wallet, and something is better than nothing. It is a caution for anyone relying on a Swiss "verified" flag as evidence. The flag records that a method was run. It does not record what the method proved.

What kind of document is this?

This is the part that decides how much weight the rule can carry.

Swiss financial rules come in layers. An Act is passed by Parliament. An ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. is made under an Act and binds. A FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. circularA FINMA document explaining how it will apply the law. It binds FINMA itself. FINMA says a circular needs no express statutory hook but must trace back to a higher rule. explains how FINMA will apply the law, and binds FINMA itself. FINMA guidanceA short notice to supervised firms (German: Aufsichtsmitteilung). FINMA says it is not a regulatory instrument and is aimed at practical effect, not legal effect. sits below all of those.

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. says so itself. On its own page for these notices:

"Die FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.-AufsichtsmitteilungGerman for FINMA guidance — a short notice to supervised firms. FINMA states it is not a regulatory instrument. ist im Unterschied zu FINMA-Verordnungen und FINMA-Rundschreiben kein Regulierungsinstrument, sondern dient der reibungslosen Anwendung von Vorschriften in der Praxis. Sie ist auf den Taterfolg, nicht auf die Rechtswirkung ausgerichtet."

In English: FINMA guidance, unlike FINMA ordinances and FINMA circulars, is not a regulatory instrument. It serves the smooth application of rules in practice. It is aimed at practical effect, not legal effect. (FINMA's own English version puts it more strongly still: guidance "does not have legal impact". The German is the authentic text, and it says slightly less.)

So where does the binding duty come from? FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. points to Article 10 AMLO-FINMA, headed Angaben bei Zahlungsaufträgen — information on payment orders. Read it and it is an ordinary travel-rule provision: send the payer's name, account number and address, and the payee's name and account number. Search the whole ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. and the German words for wallet, power of disposal and ownership appear zero times.

The rule is therefore an inference. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. reads a duty to make information travel, notes that no compliant system exists to carry it for crypto, and concludes that a firm may only send to wallets it has proved its customer controls.

That inference has been publicly questioned since the month it appeared. Writing in September 2019, Jeremy Bacharach — then a doctoral researcher at the University of Geneva's banking and finance law centre — argued that Article 10 does not support the third-party identification duty: "Die angeführte Rechtsgrundlage stellt aus unserer Sicht keine solche Verpflichtung dar" — in our view the legal basis cited imposes no such obligation. (Crypto Valley Journal, 25 September 2019.)

What a court has said

No court has ruled on the 02/2019 guidance. A full-text query of entscheidsuche.ch — which indexes the Federal Supreme CourtSwitzerland's highest court, in Lausanne. Last stop for an appeal against a FINMA decision., the Federal Administrative CourtThe Swiss court that hears appeals against FINMA decisions. Its judgments are where FINMA's legal positions get tested in public., the Federal Criminal Court and the cantonal courts — returns no decision citing it, and no decision construing Article 10 AMLO-FINMA since 2019. The single decision on that article, BVGer B-2091/2014, predates the guidance by four years.

A court has, however, decided what a FINMA guidance is. In a criminal judgment of 2 December 2021, SK.2021.17, the Federal Criminal Court convicted the head of an ICO issuer of acting as a financial intermediary without authorisation. The defendant had argued that applying FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s ICO guidance to conduct predating it would offend the principle of legality. The court answered, at E. 2.4.2:

"Im Unterschied zu FINMA-Verordnungen und FINMA-Rundschreiben stellen Aufsichtsmitteilungen und Wegleitungen gerade keine Regulierungsinstrumente dar, sondern dienen der reibungslosen Anwendung von Vorschriften in der Praxis. Sie sind auf den Taterfolg und nicht auf die Rechtswirkung ausgerichtet (Art. 7 Abs. 1 FINMAG …)."

In English: unlike FINMA ordinances and FINMA circulars, supervisory notices and guides are precisely not regulatory instruments; they serve the smooth application of rules in practice. They are aimed at practical effect, not legal effect.

So the proposition is no longer FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.'s description of itself. A federal court has adopted it, and grounded it in Article 7(1) FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG..

Three qualifications, because the case does not decide this one.

• It concerns a different notice — Guidance 04/2017 on initial coin offerings. The court states the proposition about the category, which is why it travels, but no court has applied it to the external-wallet requirement.
• The defendant was convicted anyway, and the reason matters here. The court held that the guidance did not need to bind, because the duty was already in the Act: the obligation to affiliate to an SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. is expressly in Article 14(1) of the Anti-Money Laundering Act. That is precisely where the external-wallet requirement differs. Article 10 AMLO-FINMAFINMA's own Anti-Money Laundering Ordinance (SR 955.033.0) — the detailed rules under the GwG. In German, GwV-FINMA. does not mention wallets. A court asked the same question about the 02/2019 guidance would have to find the duty in Article 10 first, and the words are not there.
• Guidance still bites, through culpability rather than through law. The court treated the defendant's knowledge of the 04/2017 notice, and FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. having drawn it to his attention, as making his mistake of law "leicht vermeidbar" — easily avoidable. He was convicted, and sentenced to 120 day-fines of CHF 440 suspended, a fine of CHF 13,200 and costs, with the judgment executed by the Federal Department of Finance rather than by FINMA.

That last point is the practical answer to "is FINMA guidanceA short notice to supervised firms (German: Aufsichtsmitteilung). FINMA says it is not a regulatory instrument and is aimed at practical effect, not legal effect. binding?". Not as a rule. Very much as evidence of what you knew.

The 2026 revision, and the thing it left out

On 12 May 2026 FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. opened a consultation on changing AMLO-FINMAFINMA's own Anti-Money Laundering Ordinance (SR 955.033.0) — the detailed rules under the GwG. In German, GwV-FINMA.. It closed on 9 June 2026. The target date for the new text is 1 January 2027. As at 24 August 2026 no results report had appeared, so everything below is about a draft.

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. gave three reasons for the revision. One of them is "dem Bedarf nach punktueller Kodifizierung der aktuell geltenden Aufsichtspraxis" — the need to write current supervisory practice into the rules, point by point. The timetable is driven by the FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s next inspection of Switzerland, expected May to July 2027; FINMA shortened the consultationThe stage where a draft law or rule is published for comment before it is adopted. In Switzerland: Vernehmlassung for statutes, Anhörung for regulators' rules. to under a month so the changes would be in force before the inspectors arrive.

So: a rewrite, explicitly to codify practice, explicitly before an international examination.

It did two things worth putting side by side.

The first is a codification. New Article 9b writes down an expectation FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. had been enforcing through practice and had, in its own words, "mehrfach öffentlich kommuniziert" — communicated publicly several times — in its annual reports for 2021 and 2023. The reason given: "dem Bedürfnis nach Rechtssicherheit sowie dem Anliegen der FATF" — the need for legal certainty, and the FATF's concern.

The second is a deletion. Article 10(3) is repealed. That paragraph let a firm use the reduced data set for domestic payments for goods and services where full compliance was "aus technischen Gründen nicht möglich" — not possible for technical reasons. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. explains that it existed to treat payments to and from Liechtenstein as domestic, and that the QR-code changeover of 1 July 2020 made it pointless. It also records that the paragraph "war jedoch nicht mit den FATF-Recommendations vereinbar" — was not compatible with the FATF Recommendations.

The external-wallet requirement appears nowhere. Searched right through, the draft and its seventeen-page explanatory report never use the words 51a, virtuell, Wallet, Verfügungsmacht, Blockchain or DLT.

Set the three facts together and the question asks itself. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. had a codification vehicle open. It had a stated reason — legal certainty. It had an international examination coming. It had a worked example, in the same instrument, of writing down a practice it had announced through annual reports. And it left its strictest crypto requirement exactly where it was.

There is also a smaller point with a longer reach. Article 10(3) is the only place in Article 10 that excuses a firm because something is technically impossible. The 02/2019 guidance rests on exactly that idea — the rule applies "as long as" a firm cannot send and receive the required information. On its face the repeal does not touch crypto: Article 10(3) is about domestic payments for goods and services. But from 1 January 2027, if the draft is adopted, the article the external-wallet requirement is read out of will contain no technical-impossibility exemption at all.

The other side of the argument

A Swiss supervisor would say this makes far too much of where a document sits.

FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. has restated the 02/2019 guidance in four annual reports. It discussed implementation with the SROsA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist.. It built an audit module for it. In 2024 it sent inspectors into SROs because of travel-rule risk. A rule that is supervised, audited and inspected for seven years is an operative rule, whatever shelf its text is on. And a firm that told FINMA its published reading of Article 10 was merely guidance, and therefore optional, would be making an argument it might win in theory and lose in every way that matters — FINMA licenses, inspects, and under FINMASAThe Financial Market Supervision Act of 2007 (SR 956.1) — the statute that created FINMA and lists what it may do. In German, FINMAG. can strip authorisation.

That is right as advice. Comply.

It is incomplete as analysis, for two reasons that survive it. The duties are scattered and unconsolidated — five documents over six years, never published as a set. And the codification point stands on its own facts: FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. did codify a comparable practice in 2026, for stated reasons that apply at least as strongly here, and did not codify this one.

Reading for practitioners

If you are a firm. The status point is not an escape route. A federal court has said FINMA guidanceA short notice to supervised firms (German: Aufsichtsmitteilung). FINMA says it is not a regulatory instrument and is aimed at practical effect, not legal effect. is not a regulatory instrument, and in the same judgment treated knowledge of the guidance as making a mistake of law inexcusable. Departing from it is a decision to be defended on the ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act., not a free option. Do not treat the 02/2019 guidance as the specification. Read the 2020 and 2022 annual reports as well, because that is where the accepted methods live. Document which method you used and when. If you rely on whitelistingChecking an address once, then trusting it for later transfers without repeating the check., record the re-check interval you set and why — FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. leaves that interval to you, which is discretion you will be asked to justify.

If you are checking a Swiss counterparty. Ask which supervisor it answers to. Firms outside a banking licence are supervised by one of the eleven FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone.-recognised SROsA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist., not by FINMA: AOOS, ARIF, OAD FCT, PolyReg, SRO SLV, SRO SAV/SNV, SRO-SVV, SRO SVIG, SO-FIT, SRO-Treuhand Suisse and VQF. FINMA's own list is here. The external-wallet requirement reaches SRO-supervised firms through their SRO's rulebook, not directly.

If you are asking a Swiss firm for records. The wallet-ownership artefact is the document worth naming in a request: the signed messageProving you control an address by using its private key to sign a text you were asked to sign. No money moves., the micro-payment, the time-boxed transfer, the screenshot. Ask which method, on what date, and when it was last repeated. "Verified" on a file is not a date.

If you are advising on what happens next. Two dates. The revised ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. is targeted at 1 January 2027 and remains a draft. The FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. inspection is expected between May and July 2027. If the external-wallet requirement is going to be written into the ordinance, the run-up to that inspection is when it would happen.

Dotted-underlined terms carry hover definitions; the full list is in the glossary. For how the two Swiss supervisory channels differ, and why FATF's rule against self-regulatory supervision did not stop Switzerland using one, see Supervised by whom. For the same travel-rule question across three jurisdictions, see Three travel rules.

Key takeaways

• The 02/2019 guidance is still in force. Nothing has replaced it and the ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. beneath it is unchanged since 1 January 2023.
• The rule has been qualified four times, entirely in annual reports — which is where the six accepted verification methods live. FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. has never published them as a list.
• FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. states that its guidance is not a regulatory instrument and is aimed at practical effect, not legal effect. The binding provision, Article 10 AMLO-FINMAFINMA's own Anti-Money Laundering Ordinance (SR 955.033.0) — the detailed rules under the GwG. In German, GwV-FINMA., never mentions wallets.
• The May 2026 revision codified a different practice for legal certainty ahead of the 2027 FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists. inspection, and left the external-wallet requirement alone.
• No court has ever cited the 02/2019 guidance. One has held that FINMA guidanceA short notice to supervised firms (German: Aufsichtsmitteilung). FINMA says it is not a regulatory instrument and is aimed at practical effect, not legal effect. is not a regulatory instrument at all — and convicted the defendant anyway, because that duty was in the Act. This one is not.
• A Swiss "verified" flag records that a method was run — it does not record what the method proved. One accepted method is a screenshot.

Sources

FINMA — the rule and its qualifications

• FINMA Guidance 02/2019, "Payments on the blockchain", 26 August 2019
• FINMA guidance register (all 59 documents) · the German landing page, for the "not a regulatory instrument" wording · register of current circulars — all read 24 August 2026
• FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. Jahresbericht 2020 (DE), pp. 43–44 — the accepted methods, whitelistingChecking an address once, then trusting it for later transfers without repeating the check. and the omnibus-wallet screenshot · FINMA Annual Report 2021 · Annual Report 2022, p. 38 — time-boxingProving control by sending an agreed amount to an address the firm supplies, inside a short window it sets. and wallet login · Annual Report 2024 — SROA self-regulatory organisation. A private body, recognised by FINMA, that supervises money-laundering compliance at firms FINMA does not supervise itself. Eleven exist. inspections and the 203/88 figures · Annual Report 2025 — nil return

Law

• AMLO-FINMA, SR 955.033.0, consolidated to 1 January 2023, on Fedlex — Art. 10
• FINMASA, SR 956.1, Art. 7 — FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. exercises regulatory powers by ordinancesA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act. and circularsA FINMA document explaining how it will apply the law. It binds FINMA itself. FINMA says a circular needs no express statutory hook but must trace back to a higher rule.
• Anti-Money Laundering Act (GwG), SR 955.0

The 2026 revision

• FINMA, consultation on the partial revision of AMLO-FINMA, 12 May 2026 — draft amending ordinanceA rule made by the government or a regulator under a power given by an Act. Binding law, but below the Act., explanatory report, key points
• FINMA's completed consultations, 2026 — no results report as at 24 August 2026

Courts

• Bundesstrafgericht, SK.2021.17, 2 December 2021 — E. 2.4.2 on the status of FINMAThe Swiss Financial Market Supervisory Authority. It licenses firms, inspects them and can shut them down — but it cannot fine anyone. supervisory notices
• Swiss court corpus queried through entscheidsuche.ch, 24 August 2026 — no decision cites the 02/2019 guidance

Standard and commentary

• FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists., The FATF Recommendations, consolidated to June 2026 — Interpretive Note to Recommendation 15, paragraph 7
• FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs, October 2021 — paras 179, 203–204, 295–297
• FATF, Best Practices on Travel Rule Supervision, June 2025
• Jeremy Bacharach, 'Verfügt die FINMA-Mitteilung 02/19 über eine ausreichende Rechtsgrundlage?', Crypto Valley Journal, 25 September 2019

Sourcing note, 24 August 2026. The section How far beyond the standard was added after FATFThe Financial Action Task Force — the inter-governmental body, created by the G7 in 1989, whose Recommendations set the global anti-money-laundering standard. Not a law-maker: its power runs through peer review and its lists.'s October 2021 guidance was obtained and read in full. It is worth saying why, because the practice's own working note had until then described FATF's treatment of private wallets as amounting to the parenthesis "(if any)" in the Interpretive Note to Recommendation 15. That is true of the Recommendations themselves and understates the position once the guidance is in view: paragraphs 179, 203–204 and 295–297 address unhosted-wallet transfers at length, and paragraph 297 floats the very restriction Switzerland had already imposed. The conclusion is unchanged and better supported — no FATF instrument requires a firm to establish who controls the receiving address — but the shorter formulation would have overstated the silence, and it has been retired before it reached this page.

Research and analysis, not legal advice. Positions stated as at 24 August 2026; the AMLO-FINMA revision was a draft on that date. The information provided is for research and educational purposes only and does not constitute legal advice.