GBBC Response to Swiss Federal Council Consultation on Stablecoins and Cryptoasset Services (FinIA Amendments)

GBBC has submitted its response to the Swiss Federal Council consultation on proposed amendments to Switzerland’s framework for stable crypto-based payment instruments and cryptoasset services.

GBBC welcomes Switzerland’s direction of travel toward a clearer and more comprehensive regulatory regime. Our response highlights targeted refinements designed to ensure the framework is legally certain, operationally feasible, proportionate, and scalable in implementation.

Our response emphasizes:

🔹 A risk-based AML/CFT model centered on clear control points (issuance, redemption, and direct relationships), avoiding infeasible secondary-market monitoring expectations.

🔹 Secondary-risk mitigation framed as capability-based and governance-led, including clarity on sanctions governance and lawful response mechanisms.

🔹 Greater clarity on authorization architecture, including bank/group participation and (where separation is intended) a standardized ring-fencing model.

🔹 A practical implementation and transition plan to support predictable supervisory timelines and orderly migration to direct FINMA supervision.

🔹 Strong and operable consumer protection mechanics on segregation in insolvency and redemption modalities, including realistic timelines and intermediated holding scenarios.

🔹 Clarification on market integrity outcomes and allocation of responsibilities to actors with meaningful control and information access.

Read the full response here.

GBBC remains committed to constructive engagement to support a Swiss framework that is trusted, coherent, and internationally competitive.