Anonymity-enhancing assets or unattributed transfers are barred outright, or barred for regulated firms.
What Switzerland actually says
A useful corrective to the assumption that a crypto-friendly jurisdiction is permissive about anonymity. The two are unrelated, and Switzerland proves it. Nothing in Swiss law bans privacy coins, and the regulator treats anonymity as a risk factor rather than a prohibited property. But since 2019 supervised institutions have only been able to move tokens to an external wallet where that wallet belongs to their own identity-verified customer, with ownership demonstrated by technical proof. There is no minimum value and no carve-out for unregulated wallets, which makes it stricter than both the FATF standard and the EU rule that followed. The practical effect is that regulated Swiss venues are closed to anonymous self-custody, by supervisory practice rather than statute.
The instruments that matter
- FINMA Guidance 02/2019, 26 August 2019
- supervised institutions may send or receive tokens to an external wallet only where the wallet belongs to their own identity-verified customer, with ownership proven by technical means
- Stricter than FATF
- no de minimis and no exception for unregulated wallets, which is a higher bar than the global standard or the EU travel rule
- Article 51a AMLO-FINMA
- a CHF 1,000 identification threshold for occasional virtual currency transactions since 1 January 2021, aggregated over 30 days rather than per day
- No privacy coin ban
- FINMA treats blockchain anonymity as an elevated money-laundering risk, not a prohibited feature
What this means for confidential transactions
Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.
Related entries
- GeorgiaEurope · The one place where privacy oversight went backwards
- TurkeyEurope · Caps, delays and a compelled purpose description
- EU AMLR Article 79Europe · Anti-money laundering · Regulation (EU) 2024/1624
- EU Transfer of Funds RegulationEurope · Travel rule · Regulation (EU) 2023/1113
- NorwayEurope · MiCA via the EEA, with a privacy-innovation sandbox
- UkraineEurope · The law that passed and never commenced
Compliant by default.
See how selective disclosure satisfies a supervisor without publishing your book to the world.