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.

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.