Since the DLT Act in 2021, Switzerland has built arguably the world's most complete legal and operational environment for tokenised securities — from Article 973d of the Code of Obligations to SDX's full integration into SIX's core post-trade infrastructure in October 2025.
Latin American issuers can use the Swiss stack today — tokenising rights under Swiss law, issuing through SDX, custodied by Swiss banks. In parallel, Swiss advisors can help build equivalent regulatory frameworks at home in Chile, Argentina, Brazil, and Colombia.
Latin America is entering a period of greater stability with rising demand for infrastructure financing that domestic capital markets cannot cover. Switzerland's DLT lead is real — but it is not permanent. Singapore, Luxembourg, and the UAE are closing the gap.
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 in October 2025 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 it should now sell it."— Dr. Verónica Pollak, C² Multiplier, May 2026
The question now is what Switzerland does with that lead. The most interesting answer lies abroad, and specifically 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, again, 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. The Chilean regulator is moving toward formal recognition of digital financial instruments. Argentina is more advanced, having already approved a set of internal regulations, with its tokenisation sandbox closing in August 2026 — after which implementation will begin. Brazil and Colombia are watching. 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 are service-based rather than capital-based.
Latin American issuers — sovereign, corporate or project-level — can use the Swiss end-to-end stack today: 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.
The friction is further reduced by Switzerland's existing treaty network with the region — including the double-taxation agreement with Chile, in force since 2010, and comparable treaties with Argentina, Colombia, Mexico and others — which gives issuers and investors a stable cross-border tax framework for the cash flows running between Switzerland and the issuer's home jurisdiction.
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.
The commercial layer follows the same logic: Latin American banks building their own digital custody and settlement capabilities will need qualified support, and the natural form of that support is partnership — joint ventures, sub-custody, white-label issuance — between Swiss banks 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.
"Switzerland's tokenisation regime is a piece of regulatory craftsmanship that has quietly produced a tradeable national asset."— Dr. Verónica Pollak, C² Multiplier, May 2026
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.
The window will not stay open indefinitely. Singapore's MAS has been active in tokenised bond pilots. Luxembourg has updated its securities law. The United Arab Emirates 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.
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. 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.
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