Column · 30 May 2026

Switzerland's Quiet Edge in Tokenisation
and How to Export It

A capital-light opportunity in Latin America

Dr. Verónica Pollak
Founder & Principal Advisor, C² Multiplier
Published 30 May 2026
Topics Tokenisation · DLT · Latin America · Switzerland
01
Switzerland's Complete Stack
Since the DLT Act (2021), Switzerland has assembled the world's most complete legal and operational infrastructure for tokenised securities — from Article 973d to SDX's integration into SIX post-trade in October 2025.
02
Latin America's Infrastructure Gap
Demand for infrastructure financing across LATAM — energy, ports, mining, real estate — far exceeds what domestic capital markets can provide. None of the major economies will have a Swiss-grade tokenisation stack within three to five years.
03
A Two-Track Export Opportunity
Track one: Latin American issuers can use Swiss infrastructure today. Track two: Swiss advisors help Latin American jurisdictions build the equivalent stack at home. Both tracks reinforce each other — and neither requires a single franc to leave Switzerland.

For decades, Switzerland's contribution to other economies has been measured in francs — lent, deposited or invested. The next contribution may not require a single franc.

Since the DLT Act came into force in August 2021, Switzerland has assembled what is arguably the world's most complete legal and operational stack for tokenised securities. Article 973d of the Code of Obligations gives ledger-based securities clean legal status. FINMA licenses the infrastructure. SIX operates the rails, with SDX now integrated into the main exchange and central securities depository following its formal incorporation in October 2025. A regulated banking layer provides custody. The Swiss National Bank, through Project Helvetia III, continues to settle tokenised bonds in wholesale central bank money — a step few jurisdictions can claim.

The volumes are still modest, but the signal is clear. More than CHF 2 billion of securities have been issued on SDX, with the World Bank, UBS and Commerzbank among the issuers. The integration of SDX into SIX's core post-trade infrastructure confirms what was previously a hypothesis: tokenisation is no longer a separate experimental track but part of the ordinary financial-market infrastructure.

The country that built this regulatory architecture should now sell it — and Latin America is the natural market.

The question now is what Switzerland does with that lead. The most interesting answer lies in Latin America. The region is entering a period of greater political and macroeconomic stability than it has known for years. Demand for infrastructure — energy transition, transmission, ports, water, urban real estate, mining projects from exploration to extraction — is rising faster than domestic capital markets can finance it. Sovereign and corporate issuers are looking for diversified funding. Local stock exchanges and bank balance sheets will not be enough.

What the region does not yet have is a regulated end-to-end environment for tokenising those rights. Chile's regulator is moving toward formal recognition of digital financial instruments. Argentina has already approved a set of internal regulations, with its tokenisation sandbox closing on 21 August — after which implementation begins. Brazil and Colombia have the potential to become active in the tokenisation field. None of them will have a Swiss-grade legal and operational stack within the next three to five years.

That gap defines a two-track opportunity, and both tracks are service-based rather than capital-based.

Track One · Immediate
Use Swiss Infrastructure Today

Latin American issuers — sovereign, corporate or project-level — can tokenise rights under Swiss law, issue through SDX, and hold the resulting instruments through a regulated Swiss banking custodian. Nothing in the architecture requires the issuer to be Swiss. Switzerland's existing treaty network with the region — including double-taxation agreements with Chile (2010), Argentina, Colombia, Mexico and others — gives issuers and investors a stable cross-border tax framework for cash flows between Switzerland and the issuer's home jurisdiction.

Track Two · Build-Out
Export the Stack Itself

Swiss law firms, regulatory advisors and infrastructure designers can help Latin American jurisdictions construct the equivalent stack at home: adapting an Article 973d-style regime to local civil-law traditions, designing FINMA-equivalent licensing for digital-asset banks, and advising on integration with existing exchanges and central securities depositaries. Latin American banks building their own digital custody and settlement capabilities will need qualified support — and the natural form of that support is partnership between Swiss institutions and their Latin American counterparts.

The two tracks reinforce each other. Issuance through Swiss infrastructure today creates the institutional familiarity, the investor base and the working precedents that make credible regulatory transposition possible tomorrow. In each case, Switzerland exports expertise and regulated infrastructure access. No franc needs to leave the country.

The Window Will Not Stay Open Indefinitely

Singapore's MAS has been active in tokenised bond pilots. Luxembourg has updated its securities law. The UAE is investing heavily. None of these jurisdictions yet matches the depth of the Swiss arrangement — but the gap is closing. Switzerland's lead is real; it is not permanent.

It is worth pausing on how unusual this combination is. Switzerland is small. Its financial-services export model has historically depended on cross-border private banking — a business under structural pressure in recent years. The tokenisation stack offers an export category that does not depend on banking secrecy, is not yet commoditised, and rests on regulatory work that is genuinely difficult to replicate.

What is missing is initiative. Switzerland Global Enterprise, the cantonal economic offices and the State Secretariat for International Finance have a unique opportunity to develop strategies that further reinforce Swiss financial-services visibility in a region actively looking for exactly this kind of expertise.

There is a temptation, when discussing law and regulation, to treat them as constraints on business. The Swiss tokenisation regime is the inverse case: a piece of regulatory craftsmanship that has quietly produced a tradeable national asset. The country that built it should now sell it.

Tokenisation DLT Act SDX · SIX Latin America Switzerland Digital Assets FINMA Capital Markets Argentina Brazil Chile

Interested in Switzerland's tokenisation infrastructure for Latin America?
C² Multiplier advises institutions on both tracks — issuance through Swiss infrastructure today, and regulatory build-out for the long term.

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