We aim to guide your institution through the meticulous process of application of a Swiss Light Bank License, leveraging our expertise in regulatory compliance, risk management, and strategic planning to establish a solid foundation for your banking operations in Switzerland. If you have questions do not hesitate to contact us at connect@swissfintechpro.com
Our team in Switzerland boasts a diverse array of professionals including lawyers, bankers, and bank auditors with extensive experience that can provide expert Global Company Activation services.
As you may know it is mandatory for a company to have a Swiss Resident Director. Of note, we will provide a resident director that has 11 years experience as CFO and CRO of a Swiss Bank and 9 years experience as senior bank auditor. He has an extensive background, expertise in Swiss financial regulation, governance, risk management, and direct experience with FINMA licensing processes. He also has a favorable reputation with FINMA. His presence alone in your company will weight in a favorable decision of Finma.
Our fees are inclusive of company incorporation, providing a resident director, company address for application period, and all the services listed below. Please contact us for a quote.
Regulatory Strategy and Advisory: Development of a strategic approach to licensing, including advisory services on regulatory compliance, positioning for the Swiss market, and interaction with FINMA.
Business and Operational Plan: A detailed business plan including market analysis, operational structure, product and service offerings, and strategies for growth and sustainability. This plan should also detail the technological infrastructure to support banking operations.
Risk Assessment and Management Framework: Comprehensive documentation of the risk management strategy, including identification, assessment, mitigation, and monitoring of financial, operational, compliance, and reputational risks.
Compliance and AML Framework: Development of a robust compliance program tailored to meet Swiss regulations, focusing on Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) requirements.
Financial Projections and Capital Adequacy Planning: Detailed financial models projecting income, expenses, cash flow, and capital adequacy, demonstrating the institution’s financial viability and compliance with capital requirements.
Corporate Governance Structure: Documentation outlining the governance structure, roles and responsibilities of the board of directors and senior management, and policies ensuring effective oversight and internal controls.
IT and Cybersecurity Strategy: A plan detailing the institution’s IT infrastructure, digital banking solutions, data management practices, and cybersecurity measures to protect against online threats and ensure data integrity.
Client Onboarding and Service Policies: Procedures for client onboarding, account management, and service delivery, including customer service policies and dispute resolution mechanisms.
Legal Documentation and Regulatory Filings: Preparation and submission of all required legal documents, including the institution’s articles of incorporation, regulatory filings, and any necessary legal opinions or analyses.
Audit and Internal Controls: Establishment of internal audit functions and controls to regularly assess compliance with laws, regulations, and internal policies.
Human Resources and Training Programs: Strategies for recruiting qualified personnel, including training programs on compliance, risk management, and customer service.
Market Entry and Product Launch Strategy: Plans for market entry, marketing, product launch, and customer acquisition to ensure a successful start to operations.
Environmental, Social, and Governance (ESG) Strategy: An ESG strategy reflecting the institution’s commitment to sustainable banking practices and social responsibility.
Deposit Taking: Companies can accept public funds up to CHF 100 million. This is particularly relevant for FinTech firms that wish to manage customer funds without extending loans or paying interest on deposits.
Payment Services: Offering payment processing and money transfer services. This can include domestic and international transfers, payment transaction services, and mobile payment solutions.
Custody Services: Holding and managing clients’ electronic money or digital assets, albeit with certain restrictions and within the scope defined by the Swiss Financial Market Supervisory Authority (FINMA).
Card Services: issuing and acquiring.
Innovative Financial Services: The license is designed to accommodate innovative business models that may not fit the traditional banking mold. This could include blockchain-based financial services, provided they comply with the regulatory framework and do not involve speculative investments or operate as securities exchanges.
| Banking license | FinTech license | |
| Public deposits | Unlimited | Max. CHF 100 million |
| Use of deposits | Lending and deposit business | Deposit business only (no interest margin business) |
| Minimum capital | CHF 10 million | CHF 300,000 or 3% of deposits |
| Capital and liquidity requirements | As per Banking Act | None |
| Supervision and monitoring | Normal auditor; annual audits | Reduced requirements on auditor; reduced audit frequency by request |
| Accounting | As per Banking Act | As per Swiss Code of Obligations |
| Deposit guarantee | As per Banking Act | None |
| Organisational requirements | Comprehensive, as per Banking Act | Exceptional relaxation of requirements possible |
Reasons for Applying: Explanation of the motivation and intentions behind seeking the license.
Proposed Activity and Organization: Description of the business activity, geographical scope, target clientele. Certified commercial register extract, business premises, infrastructure, personnel, and group company details.
Share Capital: Structure, allocation, nominal values, and subscription details.
Participants: List and graphic representation of direct/indirect holders of 9% or more. Beneficial ownership details and control or influence agreements.
Personal details, CV, references, criminal and debt enforcement records, participation declarations, and identification documents.
Similar requirements as for individuals, plus articles of association, commercial register extract, financial situation, group structure, and legal proceedings declarations.
Details on the governing body and executive board, including composition, powers, personal information, identification, CVs, and references.
Detailed business activities and processes, business plan with financial projections, IT and operational readiness, organizational structure, risk management, compliance policies, outsourcing plans, and public deposit handling.
I.5 Meeting Financial Requirements:
Evidence of minimum capital requirements compliance, capital trends, and financing sources.
I.6 Regulatory Audit Firm:
Acceptance noticed and completed questionnaire for the regulatory audit mandate.
I.7 Additional Group Requirements:
Organizational chart with license information, representation of voting rights, and capital shares.
Detailed justification for any changes, risk analysis, and tracked document modifications. Prior FINMA approval is required for significant changes.
Documentation and Submission:
All information must be thoroughly documented, with all relevant forms completed and signed. The application should be structured to facilitate easy review by FINMA, ensuring that all aspects of the license requirements are addressed comprehensively.
The scope of services outlined in this proposal has been meticulously designed to address the multifaceted requirements set forth by FINMA.
By embracing a thorough preparation strategy, your institution will not only meet regulatory expectations but also position itself as a resilient and innovative player in the banking sector.
We are committed to supporting you through this complex process to achieve your strategic objectives.
We encourage you to contact us to further discuss your strategy and how we can assist you in this endeavor at connect@swissfintechpro.com
