Regulatory Advice to a Start-up on the Structuring and Launch of a Non-Custodial Wallet for Digital Assets

Zürcher Rechtsanwälte AG advised a start-up on the legal structuring and implementation of a non-custodial wallet under Swiss financial market regulation. The regulatory analysis focused in particular on the question of whether the wallet provider would be subject to the Swiss Anti-Money Laundering Act («AMLA»). Due to the absence of control or disposal power over digital assets of the wallet provider, an application of the AMLA as well as other Swiss financial market laws could be excluded.

Sebastian Hepp (Partner, Blockchain / Digital Assets) acted as lead counsel in advising the start-up and was responsible for the regulatory analysis of the non-custodial wallet infrastructure.