Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Circle (USDC) is a stablecoin issuer with freeze authority over your tokens. Circle is FINMA-registered (2023); USDC approved for Swiss banking — first stablecoin with FINMA approval Swiss lawyers file formal appeals with Circle (USDC)'s compliance team. Free case review within 24 hours.
Circle is FINMA-registered (2023); USDC approved for Swiss banking — first stablecoin with FINMA approval
FINMA classifies crypto under existing financial regulation; SRO membership (Self-Regulatory Organization) required for crypto businesses; Crypto Valley (Zug) is a global hub
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
What this means for you: Circle (USDC) is a stablecoin issuer with freeze authority. The freeze is at the smart contract level — not an exchange freeze. We appeal directly to Circle (USDC)'s compliance team and coordinate with FINMA (Swiss Financial Market Supervisory Authority) if the freeze is related to a regulatory request.
under AMLA, you can complain to FINMA; also Swiss Banking Ombudsman (Bankenombudsman); professional secrecy under Swiss Criminal Code §321
Under AMLA (Anti-Money Laundering Act, GwG) + FinSA (Financial Services Act), Circle (USDC) must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Circle (USDC) doesn't meet these obligations, we escalate to FINMA (Swiss Financial Market Supervisory Authority) and file a formal legal submission. For a broader comparison of how Switzerland's rules stack up against other jurisdictions, see our AML laws by country reference.
wealth tax (varies by canton, 0.1-1%); capital gains on private wealth are tax-free if held as private asset
If your Circle (USDC) account is frozen, you may still need to declare your crypto holdings on your Switzerland tax return — even if you can't access them. Under Switzerland law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a Swiss tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the FINMA (Swiss Financial Market Supervisory Authority) and tax authority explaining the situation.
A Swiss user had Circle (USDC) stablecoins frozen on a centralized exchange after the issuer blacklisted the address. Under AMLA (Anti-Money Laundering Act, GwG) + FinSA (Financial Services Act), the exchange must comply with the issuer's freeze. We filed a formal appeal with the exchange and Circle (USDC)'s compliance team. The account was restored after we provided a legal submission citing FINMA (Swiss Financial Market Supervisory Authority)'s guidelines and the client's transaction history.
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Circle (USDC) account, transaction history, and Switzerland regulatory context to identify the exact trigger. Was it a TRM Labs risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with AMLA — not just Circle (USDC)'s standard templates. This includes source-of-funds proof, transaction tracing, and any required FINMA-specific forms.
We submit through Circle (USDC)'s compliance channels — not standard support. Our submission is in German, French, Italian and references FINMA guidelines. We coordinate with FINMA even though Circle (USDC) is not registered.
We verify everything works and advise on preventing recurrence on Circle (USDC). If Circle (USDC) doesn't respond within no statutory maximum; FINMA expects resolution within 'reasonable period' — Swiss law principle of proportionality, we escalate to FINMA and pursue cross-jurisdictional action in USA (Boston, MA) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.