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Crypto

The Swiss DLT Act Three Years On: Institutional Custody Comes of Age

Switzerland's DLT framework has given institutional allocators legal certainty on segregation and bankruptcy remoteness of digital assets. We assess what this means for treasury and allocation policies.

30 July 2026 1 min read Crypto

Legal certainty as a foundation

The Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology introduced the concept of ledger-based securities and clarified the segregation of crypto-based assets in bankruptcy. For institutional allocators, this addressed the most fundamental question: who owns the asset if the custodian fails?

Custody architecture

Institutional custody today is characterised by:

  • Segregated, client-specific wallets rather than omnibus structures
  • Multi-party computation (MPC) or hardware security module (HSM) key management
  • Geographically distributed cold storage with quorum-based signing
  • Independent attestation of reserves and controls

OTC execution

Block trades executed via a regulated OTC desk avoid the market impact and counterparty exposure of public order books. Settlement against pre-funded accounts and delivery-versus-payment workflows reduce settlement risk further.

Compliance first

All digital asset activity at First Horizon is subject to the same AMLA, FATF Travel Rule and sanctions-screening controls applied to traditional asset classes. We engage only with verified institutional counterparties and do not offer retail access.

This publication is for informational purposes only and does not constitute financial advice, an offer or a solicitation to buy or sell any financial instrument.

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