The New Swiss Regulatory Framework For Stablecoins And Crypto Asset Service Providers

Payment Instrument Institutions must hold any "client money" as deposits with a Swiss bank or another Payment Instrument Institution, or as HQLA with short term maturity in a bankruptcy-remote manner and segregated from their own assets. Additionally, "client money" of Swiss Payment Instrument Institutions will not be part of the Swiss deposit protection scheme, but will constitute special funds that have to be segregated for the benefit of clients or holders of Swiss Stablecoins.

For issuers of Swiss Stablecoins, the Bill stipulates that the Swiss anti-money laundering requirements will apply in full for the issuance in the primary market and for redeeming Swiss Stablecoins. On the other hand, anti-money laundering requirements for secondary market transactions may be met through transaction monitoring, blacklisting wallet addresses and being able to block, freeze or withdraw Swiss Stablecoins. Consequently, the current regulatory practice requiring a whitelisting for all acquirers