March 2018

On 16 February 2018, FINMA published guidelines (the "Guidelines") on the application of Swiss financial market regulation to initial coin offerings ("ICO").  The Guidelines do not provide new rules, but rather describe how FINMA assesses ICOs from the perspective of existing financial market legislation and the regulator's expectations in terms of information provided as part of submissions made to it.  Overall, the Guidelines provide helpful high-level clarifications on the regulatory treatment of different types of tokens.