MarketGuard | FAQ | Switzerland

Learn more about how MarketGuard AML compliance software can assist a European VASP and CASP with blockchain transaction monitoring and Travel Rule

Switzerland

Virtual Asset Service Providers (VASPs) in Switzerland are subject to the same Travel Rule regulations as traditional financial institutions. However, there are some specific guidelines that VASPs must follow to comply with the Travel Rule. Here are main highlights of the Travel Rule for VASPs in Switzerland:

Scope

Article 2 of the Anti Money Laundering Act (AMLA) outlines the scope of the Travel Rule in Switzerland, which must be interpreted in conjunction with FINMA circulars and guidance articles. Travel Rule applies to VASPs including cryptocurrency exchanges, wallet providers, custodians, OTC desks, payment processors, and decentralized exchanges.

Personally Identifiable Information

When a VASP facilitates a virtual asset transfer, they must share certain customer information with the receiving VASP. This includes the originator's name, account number (or transaction reference number if no account number is available), address, official personal document number, customer identification number, or date and place of birth. The beneficiary's name and account number should also be provided.

Threshold

In Switzerland, the Travel Rule threshold for linked virtual asset transactions is CHF 1,000 within a period of 30 days.

Enforcement

The Swiss Financial Market Supervisory Authority (FINMA) is responsible for enforcing the Travel Rule for VASPs in Switzerland. FINMA may conduct inspections and investigations to ensure compliance with the regulations, and may impose fines or other sanctions for non-compliance. Self Regulatory Organisations (SROs) also supervise VASPs.

Additional requirements

VASPs in Switzerland must verify transactions to and from external wallets of a third party and ensure that the same identity checks were carried out on the third party as if it would for its own customers. In case transactions involve an external wallet of the customer, the customer's authority over the external wallet must be verified using suitable technical measures (such as a Satoshi test)

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