Banking Access for Crypto Companies: Switzerland's Persistent Challenge
Switzerland has done more than almost any other jurisdiction to create a legal and regulatory environment in which digital asset businesses can operate legitimately. The Blockchain Act of 2021, FINMA’s technology-neutral supervisory philosophy, the fintech licence, the licensed crypto bank model, the DLT Act amendments — each of these represents a deliberate legislative or regulatory choice to integrate digital asset business into the mainstream Swiss financial system rather than marginalise it. And yet, for the founder of a crypto startup in Zug attempting to open a corporate bank account, the regulatory welcome mat can feel distinctly at odds with the experience on the ground.
The disconnect between Switzerland’s progressive regulatory stance on digital assets and the practical banking access that crypto companies actually encounter is one of the most persistent structural tensions in the Crypto Valley ecosystem. It is not a simple story — the situation has improved considerably since the early years, when blockchain foundations routinely struggled for months to open even a basic current account — but it is not a solved problem either. Understanding why requires looking at the structural incentives that govern banking behaviour, the specific risk factors that make crypto clients commercially unattractive to mainstream institutions, and the emerging solutions that have partially addressed the gap.
The De-Risking Problem
The phenomenon commonly described as “de-risking” refers to the practice of financial institutions terminating or restricting relationships with entire categories of client — not because individual clients within those categories have been assessed as high-risk and found wanting, but because the category as a whole presents risk management challenges that the institution judges to be disproportionate to the commercial return. De-risking is a rational institutional response to a regulatory environment in which the costs of AML and sanctions failures are very high and the rewards for serving high-complexity clients are limited.
For crypto companies, the de-risking calculus has been particularly adverse. The digital asset industry has been associated — in regulatory perception and in some cases in reality — with money laundering, sanctions evasion, fraud, and market manipulation. These associations are not uniformly fair, and they reflect the practices of a minority of actors in a heterogeneous industry, but they have been powerful enough to shape institutional risk appetite. A compliance officer at a major Swiss bank reviewing a client onboarding request from a cryptocurrency exchange faces a risk profile that includes: transactions with self-hosted wallets of unknown provenance, counterparties in jurisdictions with weak AML regimes, potential exposure to sanctioned entities through protocol transactions, and significant reputational risk if the client later appears in adverse media coverage.
The expected value calculation — compliance costs plus regulatory risk plus reputational risk, weighed against fee income from a crypto company that may be small, early-stage, and volatile — has historically produced a negative answer for most mainstream banks. The result has been systematic de-banking of legitimate crypto businesses that cannot demonstrate, within the time and information constraints of a standard onboarding process, that they present a manageable risk profile.
Correspondent Banking Pressure
The de-risking dynamic at Swiss banks has been amplified by pressure from correspondent banking relationships. Swiss banks that maintain correspondent accounts with major US financial institutions — necessary for processing US dollar transactions, which remain central to global crypto markets — face the additional constraint of their correspondents’ risk appetite. US correspondent banks, operating under the shadow of OFAC enforcement and the threat of deferred prosecution agreements, have been notably aggressive in de-risking their correspondent relationships with banks that serve crypto clients.
The consequence is that a Swiss bank might be willing, in principle, to bank a crypto company but unwilling to do so if the cost is the termination or restriction of its correspondent banking relationship with a US counterpart. The US dollar’s centrality to global finance gives American regulators and financial institutions extraordinary influence over the banking decisions of institutions far beyond US territory — an influence that has been exercised, whether intentionally or incidentally, in ways that have constrained banking access for crypto companies globally, including in Switzerland.
The extension of US sanctions designations to specific smart contract addresses — most notably the OFAC designation of Tornado Cash in 2022 — created a specific compliance challenge for banks whose clients had any historical interaction with designated protocols. The binary nature of sanctions compliance — either a transaction is permissible or it is not — made nuanced assessment of indirect exposure extremely difficult and pushed many institutions toward blanket avoidance rather than case-by-case analysis.
Which Swiss Banks Actually Bank Crypto
The realistic universe of Swiss banking institutions willing to provide banking services to crypto companies is significantly smaller than the regulatory framework would suggest it ought to be. The most reliable options have been, and largely remain, a small group of specialist institutions.
SEBA Bank and Sygnum Bank — the two FINMA-licensed crypto banks — are the most obvious entry points. Both are specifically designed to serve digital asset businesses and individuals, both maintain the compliance infrastructure necessary to onboard crypto clients efficiently, and both offer the core banking services (multi-currency accounts, payments, custody) that crypto companies need. The limitation is that SEBA and Sygnum are themselves relatively small institutions, their fee structures reflect the genuine cost of specialist crypto banking services, and their client capacity is not unlimited.
Bank Frick, a Liechtenstein-based private bank with a long-standing commitment to blockchain business, has been one of the most reliably accessible banking partners for crypto companies in the greater Swiss ecosystem. As a Liechtenstein institution operating within the EEA regulatory framework, Bank Frick benefits from a slightly different correspondent banking environment than Swiss-domiciled banks, and its specialist crypto compliance team has built the operational capability to onboard clients that would struggle at mainstream institutions.
PostFinance, the financial services subsidiary of Swiss Post, made a significant policy statement in 2019 when it confirmed that it would provide basic payment account services to cryptocurrency exchanges and blockchain companies that have completed a satisfactory due diligence process. PostFinance’s decision was significant both in its own right and as a signal about the direction of Swiss banking policy — a state-affiliated institution effectively normalising crypto business relationships.
Cantonal banks have been inconsistent. Some have found ways to serve crypto clients — particularly established foundations and companies with long operating histories in their canton — while others have maintained categorical exclusions. The variation reflects both internal risk appetite differences and the influence of local economic relationships with the crypto ecosystem.
De-Banking Incidents and Their Consequences
The experience of being de-banked — receiving a letter informing a company that its accounts will be closed, typically within 30 to 90 days, with limited explanation and limited recourse — has been common enough in the Swiss crypto ecosystem to have shaped industry norms around banking strategy. Companies that have lived through de-banking incidents describe the operational consequences as acute: an inability to pay staff and suppliers, frozen incoming client payments, disruption to exchange operations, and in some cases emergency restructuring of legal entity structures to preserve operational continuity.
The reputational consequences of de-banking can also be significant. A public de-banking event — whether because it becomes known in the industry or because the company discloses it in fundraising materials — raises questions in the minds of investors, partners, and counterparties about the company’s compliance standing, even when the de-banking was driven by the bank’s categorical risk policy rather than by any finding about the company’s specific conduct.
The most resilient crypto companies have responded by diversifying their banking relationships across multiple institutions in multiple jurisdictions — maintaining Swiss accounts for CHF operations, Liechtenstein or Gibraltar accounts for certain fiat gateway functions, and in some cases Singapore or Dubai accounts for Asia-Pacific operations. This geographic banking diversification adds operational complexity but reduces the single-point-of-failure risk that a sole banking relationship creates.
FINMA’s Guidance on Serving Legitimate Crypto Clients
FINMA has been notable among financial regulators in explicitly addressing the banking access problem and attempting to create clarity about Swiss banks’ obligations in relation to legitimate crypto clients. The regulator’s position — articulated in supervisory guidance and in public statements — is that banks are not legally permitted to categorically exclude entire industries from banking access simply because those industries are perceived as high-risk. Swiss banking law, read in conjunction with FINMA’s supervisory expectations, requires that risk assessments be conducted at the level of the individual client, not at the level of a generic industry category.
FINMA’s guidance has acknowledged the genuine compliance challenges that crypto clients present and has not required banks to accept every crypto client regardless of risk. But it has made clear that systematic categorical exclusion — refusing to even assess crypto companies — is inconsistent with the supervisory expectation that banks conduct genuine, individualised due diligence. This guidance has had some practical effect, particularly for well-established foundations and companies with long operating histories, clear governance structures, and clean transaction records.
The enforcement lever is limited, however. FINMA does not have the power to compel a bank to enter into a commercial banking relationship with a specific client, and the practical remedies available to a company that believes it has been unlawfully denied banking services are limited. Legal challenge through administrative proceedings is possible but slow, expensive, and uncertain.
Recent Improvements vs Persistent Gaps
The banking access situation for Swiss crypto companies has improved measurably since 2019, when the SEBA and Sygnum licensing decisions sent a clear regulatory signal, and since 2021 when the Blockchain Act legislative package was completed. The combination of clearer regulatory frameworks, the emergence of specialist crypto banking institutions, and the gradual normalisation of digital asset business within Swiss institutional culture has expanded the effective universe of banking options.
The improvements have been unevenly distributed. Large, established crypto companies — exchanges with FINMA VASP affiliations, foundations with multi-year operating histories, institutional custody providers — have generally been able to establish and maintain banking relationships, even if the process remains more burdensome than it should be. Early-stage startups, anonymous development teams transitioning to corporate structures, and DeFi protocol foundations with complex token governance arrangements face a much more challenging environment.
The persistent gap is particularly acute for companies that need fiat on-ramp and off-ramp infrastructure — the ability to convert cryptocurrency into Swiss francs or euros and back. This function is essential for any crypto business that needs to pay Swiss-based staff and suppliers, and the capacity to provide it at scale and reasonable cost remains concentrated in a small number of specialist providers.
Switzerland vs BVI/Cayman: Ease of Banking
A recurring question in the Crypto Valley ecosystem is whether the banking access challenges of Swiss domicile are worth enduring, given that alternative jurisdictions — the British Virgin Islands, the Cayman Islands, Gibraltar, Dubai — may offer either easier banking access or greater operational flexibility. The comparison is instructive but requires careful framing.
BVI and Cayman structures offer significant legal flexibility and are widely accepted for investment fund structuring, but they do not in themselves provide better banking access — BVI and Cayman companies still need banking relationships, and the pool of willing banks is comparable to or smaller than the Swiss pool. What these jurisdictions offer is lower compliance burden in certain dimensions (no FINMA oversight, simpler AML frameworks) at the cost of lower institutional credibility with sophisticated counterparties.
For companies seeking relationships with institutional investors, regulated exchanges, and major financial institutions, Swiss domicile retains a reputational premium that BVI and Cayman cannot match. The compliance burden is real, but it is the price of institutional credibility.
Practical Advice for Crypto Founders Seeking Swiss Banking
For founders building crypto companies in Switzerland and seeking banking relationships, several practical principles emerge from the industry’s collective experience.
Begin the banking relationship process early — ideally before the company launches — and before significant transaction volumes make the onboarding process more complex. A company with a clean operating history and a simple, well-documented business model is substantially easier to onboard than one that has been operating for two years with complex on-chain transaction histories.
Invest in compliance documentation upfront. A comprehensive AML/KYC policy, documented transaction monitoring procedures, a clear legal opinion on the regulatory classification of any tokens issued, and a clean corporate governance structure are the materials that banking compliance departments need to make a favourable assessment. Companies that present themselves as compliance-serious — not merely compliance-compliant — are more likely to succeed in onboarding processes.
Approach multiple institutions simultaneously rather than sequentially. Banking onboarding timelines in the crypto sector can be long, and the opportunity cost of waiting for a negative response before beginning the next application is significant.
Consider starting with a fintech licence holder or a specialist institution before pursuing a relationship with a major commercial bank. Building a track record with an institution that has the appetite and expertise to manage your account creates the documented operating history that may make a subsequent application to a larger institution more successful.
Conclusion
The banking access challenge facing Swiss crypto companies is a genuine structural problem rooted in rational institutional incentives, correspondent banking pressure, and regulatory complexity. It is not insurmountable, and the trajectory is toward improvement as specialist institutions grow, regulatory frameworks mature, and institutional familiarity with the crypto industry increases. But it remains a meaningful operational constraint that founders, legal advisers, and regulators must continue to address with practical honesty rather than aspirational optimism. Switzerland’s regulatory framework for digital assets is world-class; its banking access, for crypto companies, remains a work in progress.
Donovan Vanderbilt is a contributing editor at ZUG FINANCE, a publication of The Vanderbilt Portfolio AG, Zurich. The information presented is for educational purposes and does not constitute investment advice.