Switzerland has established itself as one of the world's leading jurisdictions for blockchain and DeFi projects, thanks to its principle-based regulatory approach and the DLT Act.
The question for DeFi-adjacent operators is not whether they need regulatory coverage, but which pathway is most appropriate.
The Swiss Regulatory Approach to DeFi
FINMA maintains that the decentralised nature of a protocol does not exempt its operators from Swiss financial market regulation. The approach is functional: what economic function does the service perform?
A Swiss-based entity providing token exchanges, lending, staking intermediation or custody may be classified as a financial intermediary under AMLA.
VQF Affiliation: Requirements and Process
For financial intermediaries not requiring a full FINMA licence, SRO affiliation through VQF provides a proportionate pathway. The process takes three to six months and involves assessment of business model, governance and compliance framework.
Once affiliated, members are subject to ongoing supervision including periodic audits and MROS reporting obligations.
Key Compliance Areas
AML compliance is the central focus. Providers must implement KYC procedures accounting for crypto-specific risks including pseudonymity and cross-border velocity.
Transaction monitoring systems are essential — our platform BlockchainAnalysis.io provides dedicated support in this area.
The 60-Day Settlement Rule
Financial intermediation is triggered when a provider holds or transfers third-party assets — but with a carve-out for transactions settled within 60 days. Careful legal assessment is required before relying on this exemption.
Conclusion
VQF affiliation provides a viable pathway for DeFi-adjacent service providers. At Advisorn, we advise on Swiss regulatory strategy, VQF affiliation and AML compliance.
For questions about this topic, contact us.
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