Opening of accounts for blockchain companies

Blockchain, DLT, AML, ICO,

Banks see blockchain technology as an opportunity with many opportunities for Switzerland as a location for finance and technology. Within the framework of its priorities, the Swiss Bankers Association SBA promotes and calls for innovation-friendly framework conditions in the field of digitisation. This also includes framework conditions that support the sustainable growth of companies with Blockchain-Nexus.

With the growth of blockchain companies, their demand for corporate accounts at banks in Switzerland has also risen. When opening an account, banks face various challenges, as the new blockchain technologies can also entail risks, particularly in the area of money laundering. Switzerland has strict legal regulations and due diligence obligations governing financial transactions. It is therefore essential for banks to carefully check the opening of an account.

The SBA recognised the challenges of opening an account for blockchain companies at an early stage and communicated both the interests and open questions of its members to various authorities. In addition, the SBA has been involved in an internal working group with member banks, including the Crypto Valley Association (CVA), to examine in detail the possible requirements and prerequisites for opening accounts for companies with points of contact with block chains and ICOs. As a result, the guideline (PDF, 132 Kb) published today by the SBA is now available in German.

Guideline distinguishes according to corporate financing

The published guideline is intended to help banks to open accounts in a differentiated manner, depending on the type of points of contact the company has with blockchain technology. The points of contact of the companies concerned are divided into different categories in the guideline with regard to the issuance of tokens (ICO) or corporate financing. The most comprehensive documentation requirements are for companies that finance an ICO using crypto currencies.

Blockchain companies without an ICO: Companies whose business model has points of contact with blockchain technology but who do not use it for corporate financing should in principle not be treated differently from other SME customers who want to open an account. They are subject to the usual strict legal regulations that regulate the opening of accounts. Companies have a duty to cooperate when opening bank relationships. They must be able to demonstrate that they know and comply with all the regulations relevant to their business model. Among other things, this is done with a meaningful business plan or adequate processes and resources.

Blockchain companies with an ICO: Companies that use blockchain technology to publicly raise capital for business purposes by issuing tokens can do so in the form of FIAT or crypto currencies. For companies whose ICO is financed by crypto currencies, higher and additional requirements should be imposed - regardless of whether they are subject to the Anti-Money Laundering Act or not. The guideline recommends that the ICO organiser applies the relevant Swiss standards regarding the origin of funds (KYC) and money laundering (AML) when accepting crypto currencies as part of an ICO. It is also proposed that the acceptance of crypto currencies within the framework of ICOs should in principle be treated at least like a spot transaction.

Guideline for practice

The guideline adopts the terminology and classification of tokens in accordance with FINMA's Guide to ICOs of 16 February 2018 and builds on the SBA's Code of Conduct on Due Diligence (CDB), supplemented by blockchain-specific aspects.

The guideline does not define any binding minimum standards. Institution-specific directives issued by SBA members always take precedence over these. Each bank bears responsibility for its business activities.

With this guideline, the SBA supports the best possible framework conditions for a diverse Fintech ecosystem. Business accounts are an important infrastructure service. The banks have an interest in business relationships in this growth area. At the same time, it should be emphasised that the due diligence obligations in force are binding and there is no right to open an account. The integrity and reputation of the Swiss financial centre must remain the top priority for all market participants.

Berne, 21 September 2018, Swiss Bankers Association

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