Stage five: AML onboarding and the travel rule

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An issuer of payment tokens in Switzerland is a financial intermediary under the AMLA from the moment the tokens are transferable, and must identify the participants in the sale, establish beneficial ownership, apply a risk-based approach and report suspicions to MROS.¹ That means a know-your-customer process for every purchaser in the sale, which is why public sales in Switzerland run through an SRO-affiliated issuer or a regulated distributor with an onboarding platform. The CHF 1,000 threshold below which exchange transactions may proceed without identification applies to exchange transactions. It does not cover a token sale in which the issuer creates a business relationship with the purchaser.²

In Singapore the AML regime attaches to the licensee, so an issuer that needs no PSA licence has no statutory AML duty, while a licensed distributor applies MAS Notice PSN02 in full, including the travel rule for transfers of digital payment tokens.³ The delivery of purchased tokens to the participants' wallets at the token generation event is a transfer to which the travel rule may apply if executed by a licensee. The distribution mechanics should therefore let participants claim their tokens from a smart contract after onboarding, with the issuer never acting as a transfer intermediary.

Notes

AMLA, SR 955.0, Art. 2 para. 3 lit. b (issuance of means of payment as financial intermediation), Arts 3 to 6 (due diligence) and Art. 9 (reporting); FINMA ICO Guidelines 2018, section 3.4. Part F, Chapters II and III. ↩
Anti-Money Laundering Ordinance-FINMA of 3 June 2015 (AMLO-FINMA; GwV-FINMA), SR 955.033.0, Art. 51a (threshold of CHF 1,000 per thirty days for exchange transactions in virtual currencies). Part F, Chapter III. ↩
MAS Notice PSN02, "Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service", as amended, paras 6 to 8 (customer due diligence) and para. 13 (value transfers; travel rule). Part L, Chapters II and III. ↩

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.

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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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