Stablecoins & payment structures

Possibly, after checking the product against the sandbox conditions. The CHF 1 million public-deposit limit is only one part of that review: permitted use of funds and advance customer disclosures also matter. AML requirements and any other regulatory triggers remain relevant. Define monitoring and a lawful next step before approaching the limit.

The analysis follows what the holder owns or can claim, how the reserve is held and how the token is used. Depending on the design, banking, collective-investment, securities and AML rules may become relevant. A reference to a stable price does not determine the result.

A promise to repay money can create different regulatory consequences from a claim to assets or an interest in a pool. Timing, conditions and the identity of the debtor also matter. We review the legal promise together with the reserve and operational process used to honor it.

Not every structure has the same treatment. Deposit-taking rules, relevant exceptions and any alternative authorization route must be assessed against the precise design. A guarantee or reserve arrangement should not be treated as a universal shortcut around licensing.

Its terms and coverage must satisfy the conditions of the route being relied on. We examine who can claim, what events are covered and how repayment would work. A guarantee does not, by itself, resolve the issuer’s AML, offering or cross-border obligations.

Reform proposals must be distinguished from law in force. We check whether a new category has been enacted, its commencement date and any transition provisions before using it in a launch plan. Until then, the structure must fit an available regulatory route.

Issuance and related payment activity can create AML duties. The issuer needs to understand relevant customer and holder relationships, transfer mechanics and intermediaries. We assess how identification, monitoring and escalation can operate throughout the model, including secondary circulation where relevant.

The reserve model should address eligible assets, custody, access, reconciliation and the link to redemption obligations. Contracts and customer disclosures must match the actual arrangement. Legal review also considers who bears shortfalls and what happens if the issuer or a provider becomes insolvent.

Look at the holder’s enforceable rights and how assets are managed. Repayment claims can raise deposit questions; collective investment of pooled assets can raise fund questions. The token interface does not change the need to analyze those underlying relationships.

An inquiry may help where classification or a critical structural assumption remains uncertain. The submission needs a settled description of rights, reserve flows and participants. We identify the question that needs clarification and distinguish the authority process from our own legal assessment.

Swiss compliance does not establish compliance with MiCA. Asset-referenced and e-money token rules, issuer status and the activities of distributors or service providers require separate assessment. The planned currencies, holders and marketing jurisdictions should be identified early.

The schedule depends on classification, provider commitments, documentation and any necessary authority process. Reserve custody, banking access and technical controls can be important dependencies. We set milestones after reviewing the model rather than assume that all stablecoins follow the same launch timetable.

Yes. The work can cover a fiat payment flow, a stablecoin or a combined model. We assess customer claims and each participant’s responsibilities, then prepare the agreed regulatory analysis and documentation. Technical implementation and any additional jurisdictional work are scoped separately.