Dirk Spiegel’s assessment: Are your crypto activities FINMA-compliant?

25/03/2026

With FINMA Circular 2026/1 the regulator makes it clear: crypto is no longer an experimental playground. Custody, governance and accountability are at the core – and anyone who safeguards or effectively controls crypto assets assumes full regulatory responsibility.

Dirk Spiegel, CEO at velaw, summarises the key points of the circular and explains what supervised institutions should do now in practical terms.

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Key points at a glance

No special regime for crypto: The circular does not create new laws – it clarifies how existing requirements under FINMASA, FINIA and AMLA are to be applied to crypto business models.
The biggest risks lie in the organisation: The issue is not the code, but governance, processes and outsourcing structures. Institutions must define clear responsibilities and be able to demonstrate them.
Custody means responsibility: Anyone who safeguards or effectively controls crypto assets bears full regulatory responsibility – regardless of the technical implementation.

Act now: The circular is already in force. The key question: Are your compliance structures and your legal advice aligned accordingly?

Are your crypto activities truly FINMA-compliant today?

velaw supports financial institutions and crypto service providers with regulatory classification and preparation. Contact us for a free initial assessment.

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Our detailed assessment of Circular 2026/1

Autor

Bio

Dirk is the founder of Velaw AG and has more than 20 years of experience in asset management, investment funds, and private market investments. He advises international and national asset managers, banks, funds, institutional investors, and other financial intermediaries on key legal, strategic, and transaction-related issues.

He specializes in the creation and structuring of investment products, the implementation of approval procedures and advice on sales and marketing activities in Switzerland and abroad.

He has extensive experience in corporate governance, compliance and risk management as well as in the development and implementation of internal regulations, anti-money laundering concepts and control mechanisms. Previously, he was Group General Counsel and Group Chief Compliance Officer of a global asset management company listed in Switzerland and gained professional experience in Europe, the USA and Asia.