Who We Serve
We advise payment innovators and regulated financial institutions entering or expanding within the Swiss FinTech and payments ecosystem.
Digital Wallet Operators
Mobile wallet platforms, stored-value apps, and peer-to-peer transfer services requiring FinTech licence authorisation under Art. 1b of the Banking Act and fund-safeguarding structures compliant with Arts. 14–14e of the Banking Ordinance.
Cross-Border Remittance Providers
International money-transfer operators — including those using crypto settlement rails — navigating multi-jurisdictional licensing under AMLA, FINMA guidance, and EU PSD2 requirements through Liechtenstein EEA passporting structures.
Crypto-Payment Processors
Platforms bridging crypto and fiat payment rails, stablecoin issuers, and blockchain-based settlement networks requiring regulatory clarity under the DLT Act (SR 958.1) and FINMA's FinTech guidance.
What We Do
Full-spectrum legal advisory across the payment-services lifecycle — from regulatory structuring and licence applications to post-authorisation compliance.
FinTech Licence Applications
Complete FINMA licence dossiers under Art. 1b of the Banking Act, including business plans, governance frameworks, and capital-adequacy submissions.
AML/KYC Programme Design
AMLA-compliant anti-money-laundering programmes, internal directives per AMLO-FINMA, and SRO affiliation or direct FINMA AML supervision for payment intermediaries.
Payment Platform Contracts
User terms of service, merchant agreements, acquirer and PSP contracts, and data-processing addenda aligned with nFADP and GDPR requirements.
Cross-Border Structuring
Swiss-EU passporting via Liechtenstein, multi-entity architectures, PSD2 authorisation strategy, and regulatory coordination across FINMA, the Liechtenstein FMA and relevant EU competent authorities.
E-Money & Stablecoin Qualification
Regulatory classification of e-money products, digital wallets, prepaid instruments, and stablecoin issuances under Swiss financial-market law and the EU Electronic Money Directive (EMD2).
Ongoing Regulatory Compliance
Prudential reporting, capital-adequacy monitoring, client-fund safeguarding, FINMA audit coordination, and outsourcing governance in line with FINMA Circular 2018/3.
Why Switzerland
Switzerland's combination of regulatory innovation and institutional stability makes it an ideal base for payment service providers.
Purpose-Built FinTech License
Switzerland’s FinTech licence under Article 1b of the Banking Act permits acceptance of public deposits up to CHF 100 million or qualifying cryptobased assets, provided they are not invested and no interest is paid on them. FINMA grants the licence and supervises licensed institutions. Capital and organisational requirements must be assessed for the proposed business
EU Market Access via Liechtenstein
Switzerland is outside the EU and EEA, and a Swiss authorisation does not provide an EEA passport. Access through a Liechtenstein subsidiary depends on the relevant FMA authorisation, local requirements and applicable cross-border notifications—not incorporation alone.
Regulatory Sandbox for Innovation
FINMA's sandbox exemption under Art. 6 para. 2 of the Banking Ordinance allows firms to accept public deposits up to CHF 1 million without any licence, provided funds are not invested or interest-bearing. This enables early-stage payment models to launch and iterate before committing to a formal licence application.
Strong Data Protection Framework
The new Federal Act on Data Protection (nFADP), effective since 1 September 2023, aligns with GDPR while preserving Switzerland's tradition of robust financial privacy. The EU Commission's adequacy decision ensures seamless cross-border data flows for payment providers serving European clients.
Why Allegra LAW
What sets us apart in Swiss payment services and FinTech regulation.
Former FINMA Professionals
Our team includes lawyers who served at FINMA's authorisation division, Allegra LAW brings first-hand supervisory experience and detailed insight into regulatory expectations and review processes.
Dual Swiss-EU Expertise
Allegra LAW combines native fluency in Swiss financial-market law with deep knowledge of EU payment-services regulation (PSD2, EMD2, MiCAR) for seamless cross-border structuring.
Accelerated Timelines
Proprietary template libraries and established FINMA relationships allow Allegra LAW to streamline typical FinTech licence timelines, subject to regulatory review periods.
Digital Asset Edge
Allegra LAW advised on the first licence for a digital stock exchange in Switzerland, providing first-hand expertise in the regulatory treatment of blockchain-based payment infrastructure.
Boutique Precision
Efficient processes, clear timelines, and transparent fee structures. We move fast without compromising quality, keeping you informed at every stage.
Strong Network
Allegra LAW maintains extensive experience interacting with FINMA, SIX Swiss Exchange, SROs and banking associations.
Your Payment Services Journey in 4 Steps
From initial regulatory assessment to operational launch and ongoing compliance support.
1
Regulatory Scoping & Business Model Analysis
We analyse your payment model, determine whether Art. 1b FinTech licence, sandbox exemption, or full banking licence applies, and map your optimal regulatory path.
2
Licence Dossier Preparation
We prepare the complete FINMA application — business plan, governance structure, AML framework, capital-adequacy documentation, and IT security concept per Arts. 14–14e BankO.
3
FINMA Submission & Dialogue
We manage the entire FINMA submission, handle information requests, and maintain constructive regulatory dialogue throughout the regulatory review period.
4
Go-Live & Ongoing Compliance
Post-approval, we support operational launch, establish ongoing compliance monitoring, coordinate FINMA audits, and advise on regulatory developments affecting your licence conditions.
Frequently Asked Questions
Key questions about Swiss payment services and FinTech licensing.
What is the Swiss FinTech licence and who needs it?
The Swiss FinTech licence under Article 1b of the Banking Act permits institutions to accept public deposits up to CHF 100 million or cryptobased assets, subject to the applicable requirements, including that these are not invested and no interest is paid on them. FINMA assesses whether the proposed activities fit the licence. Allegra LAW advises on the regulatory assessment and application documentation.
How does the FinTech licence differ from a full banking licence?
The FinTech licence is a limited authorisation, not a full banking licence. It restricts how accepted deposits and assets may be used, and client assets are not protected by deposit insurance. The appropriate licence and its capital, organisational and supervisory requirements depend on the proposed business model. Allegra LAW advises on the applicable regulatory route.
Can a Swiss-licensed payment firm operate in the EU?
Switzerland is outside the EU and EEA, and a Swiss authorisation does not provide an EEA passport. Access through a Liechtenstein subsidiary depends on the relevant FMA authorisation, local requirements and applicable cross-border notifications—not incorporation alone.
What AML obligations apply to Swiss payment service providers?
Swiss payment-service activities may fall within the Anti-Money Laundering Act (AMLA). Applicable duties include customer identification, beneficial ownership checks, risk-based monitoring and reporting to MROS where required. The relevant supervision or SRO affiliation requirements depend on the provider’s regulatory status and activities. Allegra LAW advises on the applicable AML framework and compliance documentation.
What is the FINMA sandbox exemption?
The Swiss regulatory sandbox allows acceptance of public deposits up to CHF 1 million without a banking licence, subject to the conditions of Article 6 paragraph 2 of the Banking Ordinance. It is not a blanket exemption from financial-market regulation: AML obligations and other applicable requirements must still be assessed. Allegra LAW advises on eligibility and any authorisation needed as the business develops.