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.
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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.
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Payment Platform Contracts
User terms of service, merchant agreements, acquirer and PSP contracts, and data-processing addenda aligned with nFADP and GDPR requirements.
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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.
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Why Switzerland
Switzerland's combination of regulatory innovation and institutional stability makes it an ideal base for payment service providers.
Purpose-Built FinTech License
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Since 1 January 2019, Switzerland offers a dedicated FinTech licence under Art. 1b of the Banking Act (BankA) and Arts. 14–14e of the Banking Ordinance (BankO). The licence permits acceptance of public deposits up to CHF 100 million — provided funds are neither invested nor interest-bearing — with minimum capital of just CHF 300,000 versus CHF 10 million for a full banking license.
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EU Market Access via Liechtenstein
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While Switzerland is not an EU/EEA member, establishing a subsidiary in Liechtenstein, as an EEA member applying a legal framework closely aligned with Swiss financial-market law providing a pathway to passport payment services across all 30 EEA states under PSD2. This dual-jurisdiction strategy is well-established and well-established in regulatory practice
Regulatory Sandbox for Innovation
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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.
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Strong Data Protection Framework
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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?
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Introduced on 1 January 2019 under Art. 1b of the Banking Act (BankA), the FinTech licence allows firms to accept public deposits up to CHF 100 million, provided funds are neither invested nor interest-bearing. It is designed for payment platforms, digital wallets, and similar models that hold customer funds but do not engage in traditional lending. Minimum capital is CHF 300,000. Allegra LAW has guided numerous FinTech applicants through this process, drawing on our team’s former FINMA supervisory experience to anticipate regulatory expectations and reduce typical timelines throughout the regulatory review period.
How does the FinTech licence differ from a full banking licence?
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Under Arts. 14–14e of the Banking Ordinance (BankO), the FinTech licence requires minimum capital of CHF 300,000 (versus CHF 10 million for a full bank), imposes no deposit-insurance obligation, and applies proportionate governance requirements. However, holders cannot invest customer deposits, pay interest, or exceed the CHF 100 million ceiling. Allegra LAW advises clients on which licence path — sandbox, FinTech, or full banking — best fits their business model and growth trajectory.
Can a Swiss-licensed payment firm operate in the EU?
Switzerland is not an EU/EEA member, so direct passporting is unavailable. However, establishing a subsidiary in Liechtenstein — an EEA member applying Swiss-compatible law — provides a well-established pathway to passport payment services across all 30 EEA states under PSD2. Allegra LAW's dual Swiss-EU expertise makes us uniquely positioned to structure and execute this Liechtenstein passporting strategy, coordinating with FINMA, FMA, and EU national competent authorities.
What AML obligations apply to Swiss payment service providers?
Payment providers must comply with the Anti-Money Laundering Act (AMLA/GwG), including customer identification, beneficial ownership verification, transaction monitoring, and suspicious activity reporting to MROS. FinTech licence holders fall under either direct FINMA AML supervision or must affiliate with a self-regulatory organisation (SRO). The AMLO-FINMA ordinance sets detailed requirements for risk-based due diligence. Allegra LAW designs bespoke AML/KYC frameworks specifically calibrated to payment-services risk profiles and FINMA expectations.
What is the FINMA sandbox exemption?
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Under Art. 6 para. 2 of the Banking Ordinance, firms accepting public deposits up to CHF 1 million are exempt from licensing entirely, provided funds are not invested or interest-bearing. This "sandbox" enables early-stage testing of payment models before committing to a formal licence application. Allegra LAW helps clients determine whether the sandbox exemption applies to their specific business model and structures the transition path from sandbox to FinTech licence as the business scales.