How Hong Kong Founders Get a Switzerland Crypto License in 2026
A Hong Kong team that wants a European base often looks at Switzerland first. The country has clear crypto rules, stable banks and a long history of regulated finance. But a Switzerland crypto license is not one document you apply for. It is a set of steps, done roughly in this order, mostly in Switzerland.
This guide walks through those steps for a team starting from Hong Kong. It also covers one change this year. On 12 January 2026, FINMA, the Swiss financial regulator, published new guidance on holding crypto for clients.
Step 1: Decide what your business will do
Everything depends on this. Swiss law treats crypto businesses differently based on the activity, not the label.
Write down, in plain words, each service you will offer. For example:
- buying and selling crypto for clients
- holding clients’ crypto or their private keys
- running a platform where clients trade with each other
- issuing a token
- giving advice only
A broker of payment tokens, such as bitcoin, often starts under anti-money-laundering (AML) rules only. Holding clients’ crypto is where founders slip. If you pool it, or can use it as you like, it can count as taking deposits, and that needs a FINMA licence. A business that deals in tokens that act like securities, or runs a trading venue, also needs a FINMA licence. Getting this wrong at the start is the most expensive mistake a founder can make.
Step 2: Choose your route
For most crypto firms, there are two routes today.
The first is membership of a self-regulatory organisation, or SRO. An SRO is a private body, approved by the state, that supervises a firm’s AML work. It is the usual route for brokers of payment tokens and for payment firms. It covers AML only, not deposits or securities. The details are on the Switzerland SRO membership page.
The second is a licence from FINMA itself, such as a banking or securities firm licence. It is needed for heavier activities and takes much longer.
A third route is coming. Switzerland plans a new FINMA licence for "crypto institutions". It is still a draft. Our guide on whether a Switzerland SRO membership will still be enough after the FinIA reform explains what the draft means for a new firm.
Step 3: Set up the Swiss company
You will need a Swiss company. Most crypto firms choose a GmbH, a limited liability company, or an AG, a company limited by shares. Your adviser will explain which suits your plan and your investors.
Three points catch Hong Kong teams out:
- Swiss company law requires at least one person who can sign for the company to live in Switzerland. Your Hong Kong directors cannot fill this role from Hong Kong.
- You need a real Swiss address. A regulator and a bank will both want to see where the business is run.
- Documents from Hong Kong, such as company records and passports, usually need certified copies. Many also need an apostille, which is an official stamp that proves a document is genuine abroad.
Plan for the time these take. Collecting certified documents from Hong Kong, and sending them to Switzerland, adds weeks.
Step 4: Open a Swiss bank account
This is often the slowest step. Swiss banks ask detailed questions about crypto businesses. They want to know who owns the company, where the money comes from, who your clients are and which regulator covers you.
Start talking to banks early, while you are still setting up the company. Have a clear business plan, a list of your owners and a draft of your AML policy ready. A bank that sees a well-prepared file is more likely to say yes.
Your SRO membership, or your plan to get one, helps here. It shows the bank that someone will supervise your AML work.
Step 5: Build your AML set-up
Whichever route you choose, AML sits at the centre. You will need:
- an AML policy written for crypto, not copied from a bank
- a named AML officer who knows Swiss rules
- a process to check each client’s identity
- a process to check where crypto comes from, often with a wallet screening tool
- a way to report suspicious activity to the Swiss authorities
The SRO will review all of this before it accepts you. FINMA does the same for a licence.
Step 6: Plan how you will hold client crypto
If you will hold clients’ crypto, read FINMA’s January 2026 guidance on the risks of holding crypto for clients. FINMA says it "sets out the rules that institutions must abide by in order to keep cryptobased assets safe". It is written for supervised institutions, but it shows what FINMA looks for in any custody set-up.
In practice, that means clear answers to a few questions. Who controls the private keys? Are clients’ assets kept apart from the firm’s own? What happens to clients’ crypto if the firm fails? A plan that answers these makes both the SRO and the bank more comfortable.
Step 7: Apply, then keep up
With the company, bank, AML set-up and custody plan in place, you apply to your SRO or to FINMA. After you are accepted, the work does not stop. SRO members face regular AML audits, and FINMA firms face wider audits.
If you already hold a Hong Kong licence
Some teams already run a licensed business in Hong Kong, such as a Money Service Operator (MSO). That licence does not carry over to Switzerland. Each country licenses the firms that work inside it, so the Swiss company starts its own process.
Your Hong Kong history still helps. A team that has run an AML programme under a Hong Kong licence has some track record to show. Be clear about what that licence covers. An MSO licence from Customs is for money changing and remittance, not for crypto, so present it as AML experience and nothing more. Give the SRO or FINMA a copy of the licence and your AML audit results.
Be ready for one question in particular: how the two companies connect. If the Swiss company will serve clients that the Hong Kong company brings in, explain who does the client checks, and where the records are kept. A clear answer here saves a round of questions later.
How long does it take from Hong Kong?
No Swiss authority publishes a standard time for this whole process. The answer depends on your route, your bank and how ready your documents are. An SRO route is usually much faster than a FINMA licence. Any adviser who gives you a fixed number of weeks should tell you what it assumes.
Some founders look at buying a company that already has an SRO membership. The membership does not simply pass to you with the shares. A new owner is a change of control, so the SRO checks the new owners and managers again, and it can end the membership. You can see current Swiss companies with SRO membership for sale. If your plan is a crypto exchange, read which Switzerland crypto license a crypto exchange needs first, because exchanges face different rules.
Frequently asked questions
Can a Hong Kong company get a Switzerland crypto license?
Not directly. You set up a Swiss company, with at least one signing person living in Switzerland, and that company joins an SRO or applies to FINMA.
Do I need to live in Switzerland to run a Swiss crypto company?
You do not, but someone who can sign for the company must live there. Many founders appoint a Swiss resident director.
Is SRO membership a crypto license?
No. It is anti-money-laundering supervision, not a licence. It is the usual route for brokers of payment tokens. Taking deposits, including some ways of holding client crypto, or dealing in securities needs a FINMA licence.
What did FINMA publish about crypto custody in 2026?
On 12 January 2026, FINMA published guidance on the risks of holding crypto-based assets for clients. FINMA says it sets out the rules supervised institutions must follow to keep those assets safe.
Is opening a Swiss bank account hard for a crypto company?
It can be slow. Banks ask detailed questions about owners, funds, clients and supervision. A clear business plan and AML policy make it easier.
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*Sources: FINMA news release of 12 January 2026 on the custody of crypto-based assets; State Secretariat for International Finance press release of 22 October 2025.*