One-coin blockchain problem

In a recent expert article, we introduced the one-coin blockchain. According to FINMA Guidance 02/2019 [1], full identification will be requested from third parties in certain situations. How is this problem related to the one-coin blockchain? An understanding of this problem is important not least because the FINMA requirement is related to what is known as FATF Recommendation 16 [2].

It should first be pointed out that with the one-coin blockchain no specific relationship exists between the credit balance documented in the blockchain and the owner of the coin. As explained in [3], the coin belongs to the person in possession of the key to the last block in the chain. This is in contrast to a bank account balance, which requires an explicit, formally documented relationship between the owner of the account balance (the “beneficial owner”) and the account. Identification of the account balance is a problem that all those who have opened a bank account are sure to have encountered. The relationship between the identified person and the account is the next problem.

 

Links:

[1]https://www.finma.ch/de/dokumentation/finma-aufsichtsmitteilungen/

[2]https://www.fatf-gafi.org/media/fatf/documents/recommendations/pdfs/FATF%20Recommendations%202012.pdf

[3] https://www.eurospider.com/de/know-how/compliance/255-die-ein-m%C3%BCnzen-blockchain

Data Protection Act

The Swiss Data Protection Act underwent a complete revision in 2020, and its new version took effect on September 1, 2023, along with the new Data Protection Ordinance (DPO). The revision itself is complete, but its practical application continues to evolve. The topic of AI is particularly relevant: On May 8, 2025, the FDPIC confirmed that the DPA is technology-neutral and applies directly to all AI applications. In practice, this means, among other things, that users must know whether they are interacting with AI (transparency requirement, Art. 19), and that a data protection impact assessment is mandatory in cases of high risk—such as profiling or facial recognition (Art. 22). The Federal Office of Justice (FOJ) is drafting a consultation document on AI regulation to be completed by the end of 2026. With this, Switzerland will implement the Council of Europe's AI Convention.

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