How a Singapore group obtains a Swiss licence

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The reverse route is shorter at the first step and longer at the last. A Singapore MPI that wants to serve European customers from Switzerland must first determine which Swiss licence its activities require (see Part E, Chapter XII and Part F, Chapter II). An exchange or custodian that takes no deposits for its own account needs SRO affiliation as a financial intermediary under the AMLA. Affiliation can be obtained in three to six months from an SRO such as VQF, with a Swiss-resident AML officer, Swiss AML policies and an organisational structure in Switzerland.¹ The affiliation permits the firm to operate lawfully while any further licence is sought.

If the Swiss business will manage client assets, a FinIA portfolio manager licence from FINMA through a supervisory organisation is required, which takes six to twelve months. If it will accept crypto assets with an obligation to return them in a way that FINMA treats as deposit-taking, or will offer custodial staking of locked tokens, the fintech licence under Art. 1b BankA or a banking licence is required. That takes a year or more and demands capital and organisation on a different scale. The Singapore group's advantage is its experience with the MAS custody and segregation regime, which is stricter than most Swiss SRO requirements and which FINMA will recognise. Its disadvantage is that MAS's retail restrictions will have shaped its products, whereas the Swiss market expects the full product set.

The two routes illustrate the comparison that runs through this Part. Switzerland offers a graduated entry: SRO affiliation first, licences as the business grows. Singapore offers a single gate that opens slowly and admits only firms that are already complete. A group that wants both should start where it can operate soonest and apply to the other hub from a base of regulated operations, which in most cases means Switzerland first and Singapore second.

Notes

Anti-Money Laundering Act (AMLA; GwG), SR 955.0, Art. 14 (affiliation of financial intermediaries to an SRO) and Art. 2 para. 3 on the definition of financial intermediary; see Part F, Chapters I and II. ↩

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

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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.

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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.

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