FINMA

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Document	Date	Subject
FINMA Guidance 04/2017: Regulatory treatment of initial coin offerings	29 September 2017	First statement that ICOs may fall under banking, securities, collective investment or AML law; announcement of investigations; Part E.
Guidelines for enquiries regarding the regulatory framework for initial coin offerings (ICO Guidelines)	16 February 2018	Payment, utility and asset tokens; hybrid tokens; information required for a no-action request; Part E, Chapter I.
Supplement to the ICO Guidelines: stable coins	11 September 2019	Classification of stablecoins by the asset they reference; indicative assessment of the Libra project as a payment system requiring a licence; Part E, Chapter VII.
FINMA Guidance 02/2019: Payments on the blockchain	26 August 2019	Travel rule for Swiss financial intermediaries without the FATF exception for unregulated wallets; proof of control for transfers to external wallets; Part F, Chapter IV.
FINMA Guidance 08/2023: Staking services	20 December 2023	Conditions under which staked assets remain custody assets protected in bankruptcy; direct and indirect staking chains; information duties; Part E, Chapter VIII.
FINMA Guidance 06/2024: Stablecoins	26 July 2024	Risks of stablecoin issuance for banks giving default guarantees; identification of holders; reputational and legal risk; Part E, Chapter VII.
FINMA Risk Monitor	Annual, November	Crypto and cyber risks named among the principal risks for supervised institutions; Part C, Chapter VI.
FINMA fact sheets "Virtual currencies" and "Initial coin offerings"	Updated periodically	Consumer-facing summaries of FINMA's position; Part E.
FINMA Circular 2008/3 (as amended): Public deposits with non-banks	Amended 2019 and 2021	Deposit definition, settlement accounts and the sandbox for token issuers; Part E, Chapter II.
FINMA Circular 2016/7 (as amended): Video and online identification	Amended 2021 and 2024	Remote onboarding of crypto clients; Part F, Chapter III.
FINMA enforcement reports	Annual	Published summaries of crypto-related enforcement including liquidations of unlicensed issuers; Part H, Chapter IV.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.