--- title: Swiss AML & VASP Regulatory Partner entity: SwissChain Holding SA jurisdiction: Switzerland doc_type: infrastructure status: in_progress last_reviewed: 2026-03-09 owner: TBD evidence_level: public source_urls: [] related_docs: [] --- # SCRYPT Execution Counterparty, Regulated Liquidity & Operational Custody Infrastructure (Regulatory & Technical Memorandum) ## I. Systemic Role within SwissChain Control Architecture Within SwissChain’s overall control architecture, SCRYPT is positioned as the primary regulated execution counterparty and liquidity provider used by SwissChain’s operating subsidiaries to access crypto markets, stablecoins, and certain regulated digital asset strategies. The subsidiaries do not route client orders directly to anonymous public order books; instead, they transact with a single Swissregulated counterparty that aggregates liquidity and provides an institutionalgrade execution and settlement environment. In this model, strategic custody remains with SwissChain’s operating subsidiaries on DFNS (self-custody MPC), where client assets are held “at rest.” When a market operation needs to be executed, the relevant assets are temporarily transferred from DFNS wallets to accounts/custody at SCRYPT, which in turn uses Fireblocks (MPC) and Coincover for the hot/warm execution layer, and are then repatriated to self-custody on DFNS once execution is complete. This sequence clearly separates strategic storage (DFNS, under the subsidiaries’ control) from execution and liquidity (SCRYPT, under Swiss licences), and aligns with FINMA Guidance 01/2026 on cryptoasset custody and expectations for robust infrastructure and governed delegation. ## II. Legal Nature, Regulatory Perimeter and Market Positioning SCRYPT operates through two distinct Swiss entities, each with a clearly defined regulatory perimeter. SCRYPT Digital Trading AG is a financial intermediary that is a member of VQF (Verein zur Qualitätssicherung von Finanzdienstleistungen), subject to annual AML audits under the Swiss AntiMoney Laundering Act. SCRYPT Digital Investments AG is licensed by FINMA as a portfolio manager and supervised by FINcontrol Suisse AG under FinSA, allowing it to offer regulated crypto asset management strategies to professional and institutional clients. As a counterparty, SCRYPT positions itself as a “single licensed counterparty” for institutional clients: SwissChain’s subsidiaries do not trade directly on fragmented exchange order books against unknown participants but face SCRYPT as their sole bilateral counterparty, while SCRYPT itself connects to toptier venues and market makers to source liquidity. Public information indicates that SCRYPT serves over 130-200+ institutional clients across more than 40 jurisdictions (Europe, LATAM, Middle East, APAC), has processed cumulative volumes in the “billions,” and reported over USD 25 billion in trading volume by mid2025. SCRYPT offers a service suite covering 24/7 OTC/spot trading, stablecoin rails, MPCbased custody, staking and regulated crypto asset management strategies (e.g. Crypto Growth, Bitcoin Growth, Nexus Yield) under FINMA supervision via SCRYPT Digital Investments AG. ## III. Certification and Assurance Framework SCRYPT does not publish its own ISO or SOC 2 certifications at group level, but its operational custody and execution stack is explicitly built on Fireblocks and Coincover. SCRYPT highlights that its custody is “built on Fireblocks” and leverages Fireblocks’ institutional MPC infrastructure, certified HSMs and established control environment (including SOC 2, ISO, FIPS 1402 at Fireblocks level) as the underlying technology for key protection and transaction processing. Coincover provides additional lossmitigation and continuity tools for key loss and access recovery, adding an insurancestyle layer to operational and counterparty risk management during execution. On the regulatory side, SCRYPT’s anchoring in Swiss law and supervision by VQF and FINcontrol Suisse provides a prudentially robust environment. VQF imposes detailed AML, governance, internalcontrol and reporting requirements, while FINMA’s portfoliomanager licence entails risk management, assetsegregation, compliance and organisational standards tailored to institutional clients. In combination with FINMA Guidance 01/2026 on crypto custody (technical robustness, operational risk management, asset segregation, use of prudentially supervised custodians), this allows SwissChain’s operating subsidiaries to argue that delegation of execution and operational custody to SCRYPT satisfies the expected standards for Swisssupervised institutions. ## IV. Core Technical Architecture and Control Surface SCRYPT provides an execution and settlement infrastructure built on Fireblocks, combining MPC, certified HSMs and an institutional network of exchanges and market makers. SCRYPT’s custody offering consists of hot, warm and cold layers, with client and assetspecific subwallets and granular accesscontrol and policy management, while Fireblocks acts as the custody and connectivity engine to trading venues and stablecoin rails. This architecture enables 24/7 trading with real-time monitoring, while giving institutional clients a dashboard and API to monitor balances, orders, settlements and transfers. For asset management, SCRYPT Digital Investments AG uses this infrastructure to implement regulated strategies such as Crypto Growth, Bitcoin Growth and Nexus Yield, designed to generate performance while prioritizing capital preservation and risk management under FINMA and FINcontrol Suisse oversight. On the market side, SCRYPT aggregates liquidity from “top venues & market makers” to deliver competitive spreads and reduce slippage and prefunding requirements, with clients facing SCRYPT as a single counterparty rather than fragmented exchange order books. The platform supports several hundred assets (spot, major stablecoins, BTC/ETH and other large caps) and offers FX/stablecoin rails to facilitate inflows and outflows in fiat and stablecoins. ## V. Risk Mitigation Mechanics and Residual Risk For SwissChain’s operating subsidiaries, SCRYPT mitigates several structural risks inherent in accessing crypto markets. First, using a Swissregulated counterparty (VQFsupervised intermediary plus FINMA-licensed portfolio manager) reduces offshore counterparty risk and legal uncertainty associated with unregulated exchanges or brokers in weak-supervision jurisdictions. Second, by relying on Fireblocks and Coincover for the hot/warm custody layer, SCRYPT offers an execution environment where operational keys are protected by institutional MPC infrastructure and lossmitigation tools, thereby reducing the probability and impact of key compromises or operational incidents during trading. The complementarity with DFNS further strengthens the risk profile: longterm custody remains directly under the control of SwissChain’s subsidiaries through DFNS (distributed MPC, key nonreconstruction, independent cryptographic audits), while SCRYPT/Fireblocks holds assets only for the operational window required to execute trades. This model is consistent with FINMA expectations on custody and outsourcing: assets can be held in segregated form and, where delegation occurs, it is to a prudentially supervised third party in Switzerland, backed by a robust, marketrecognized infrastructure. Residual risk nonetheless includes concentration of execution and liquidity provision in a single provider, indirect dependence on Fireblocks and Coincover for the hot/warm layer, and the inherent market and counterparty risks of OTC activity (temporary exposure to SCRYPT credit risk and settlement risk). In addition, SCRYPT does not publicly disclose full operational metrics (detailed RTO/RPO, incident statistics, stress tests), so SwissChain’s subsidiaries must supplement public information with periodic underNDA reviews of audit reports, resilience controls and assetsegregation processes as part of their vendorrisk governance. ## VI. Integration with SwissChain Subsidiaries and Control Flows In the target operating model, SwissChain’s operating subsidiaries integrate SCRYPT as their execution counterparty within order and settlementprocessing chains. Client onboarding, identity verification, KYC/KYB, sanctions/PEP screening and Travel Rule compliance are handled upstream via Sumsub and Notabene, according to grouplevel policies tailored by each subsidiary to its regulatory perimeter. Once a client is approved and an order is cleared by compliance and risk, the subsidiary orchestrates a transfer of assets from its DFNS wallets (self-custody) to SCRYPT accounts for execution, with operational keys managed on Fireblocks at SCRYPT during the trading window. Typical flows are sequenced as follows: - Client onboarding and CDD in Sumsub; sanctions/AML and Travel Rule checks in Sumsub/Notabene. - Internal order approval at subsidiary level (including risk limits and product eligibility). - Transfer of the required asset amount from DFNS wallets to SCRYPT for execution, under MPC approval policies defined by the subsidiary. - Execution and settlement via SCRYPT/Fireblocks, with real-time reporting back to the subsidiary. - Posttrade repatriation of assets from SCRYPT back to DFNS wallets for longterm storage. This DFNS-SCRYPT coupling allows subsidiaries to align execution capacity strictly with the risk management and compliance decisions taken upstream, while minimizing the time assets spend in external hot/warm custody. ## VII. Auditability, Supervisory Defensibility and Strategic Implications SCRYPT materially enhances the institutional defensibility of SwissChain’s groupwide architecture. Using a Swiss counterparty with dual supervision (VQF plus FINMA portfoliomanager licence), serving 130-200+ institutional clients across 40+ jurisdictions and processing tens of billions in trading volume, allows SwissChain’s subsidiaries to demonstrate that they operate within a Swisssupervised crypto services ecosystem rather than via unregulated offshore venues. At the same time, SCRYPT’s reliance on Fireblocks and Coincover as the base for operational custody provides an infrastructure that banks, regulators and auditors already recognize, facilitating acceptance of SCRYPT as custodian/execution partner in due diligence processes. Strategically, the “technology holding + operating subsidiaries + regulated partners” architecture adopted by SwissChain matches supervisory expectations: - The holding provides technology (DFNS, Sumsub, Notabene, orchestration) and governance. - Operating subsidiaries hold local licences and manage client relationships. - Critical functions are encircled by toptier regulated partners: DFNS for selfhosted custody, SCRYPT for Swisslaw execution counterparty and liquidity, Sumsub/Notabene for AML and Travel Rule. In this configuration, SCRYPT can be presented to bank boards, listing committees, auditors and regulators not as a simple trading service but as a control pillar enabling SwissChain’s subsidiaries to access liquidity and markets while adhering to the highest available standards of supervision, custody and transparency under the postGuidance FINMA 01/2026 Swiss framework.