On 26 August 2019, the Swiss Financial Market Supervisory
Authority FINMA ("FINMA") published its Guidance 02/2019.
Therein, FINMA provides new insight into how Swiss anti-money
laundering rules apply in a blockchain environment.
1. FINMA Guidance 02/2019 Payments on the blockchain
In June 2019, the Financial Action Task Force (FATF) issued its
guidance on virtual assets and virtual asset service providers
concluding that the effective implementation of anti-money
laundering measures requires that information about the client as
well as the beneficiary is transmitted when a token is being
transferred. In the implementation of this recommendation, FINMA on
26 August 2019 published its guidance 02/2019 ("Guidance
02/2019") providing some helpful insight into how the Swiss
anti-money laundering regime applies to transactions in a
blockchain environment.
