Soda Labs

Switzerland

Crypto-friendly and strict on anonymity at once

JurisdictionEuropeRestricts anonymity

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.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.