Crypto Custody: Switzerland vs Global Custodians Compared

The Institutional Custody Imperative

Institutional digital asset management begins with a single, non-negotiable requirement: custody infrastructure that survives the failure of the custodian. The collapse of FTX in November 2022, which left institutional clients as unsecured creditors of a bankrupt estate, crystallised what many compliance officers had long argued in theoretical terms — that custodial counterparty risk in digital assets is not merely a technology problem but a legal and jurisdictional one.

This comparison examines the global institutional crypto custody landscape through the lens of that fundamental requirement, placing Switzerland’s custodians in systematic comparison with their global counterparts across ten dimensions that matter for institutional investors: regulatory status, insurance, key management technology, on-chain capability, fee structure, client minimums, geographic availability, asset coverage, DLT Act insolvency protection (Switzerland only), and the qualified custodian question.

The Global Custody Landscape

Coinbase Custody: Scale Leader

Coinbase Custody Trust Company holds the largest institutional digital asset AuC of any custodian globally, estimated at over $100 billion as of 2025. Its competitive advantages are scale-derived: the deepest liquidity relationships, the broadest asset coverage (over 250 assets supported in institutional custody), and the strongest staking infrastructure of any regulated custodian.

Coinbase Custody Trust Company is a New York State-chartered limited purpose trust company, regulated by the New York Department of Financial Services. This regulatory standing provides meaningful credibility — a NYDFS charter is not trivially obtained — but does not provide the insolvency protection equivalent to Switzerland’s DLT Act. In a Coinbase Custody insolvency, client assets would be subject to New York bankruptcy proceedings, and while trust law provides significant protections, the precise recovery mechanism is not guaranteed by statute in the way Swiss law guarantees it.

The Coinbase Custody offering is embedded within the broader Coinbase Prime infrastructure, which provides clients with integrated execution, custody, staking, and financing from a single counterparty. For US-domiciled institutional clients, this integrated offering is compelling. For European and Asian institutional clients with regulatory requirements for custodian geographic diversification, Coinbase’s US-centricity is a limitation.

Fidelity Digital Assets: Institutional Pedigree

Fidelity Digital Assets, the digital asset subsidiary of Fidelity Investments, brings a different competitive proposition: Fidelity’s 75-year institutional investment management track record extended to digital asset custody. Fidelity Digital Assets has operated since 2018, making it one of the longest-established institutional crypto custodians.

Fidelity Digital Assets LLC holds a New York State virtual currency licence (BitLicence) and is registered as a Money Service Business with FinCEN. Its custody infrastructure uses proprietary cold storage technology, emphasising air-gapped key material and physical security over programmable MPC approaches. This conservatism reflects Fidelity’s institutional culture: the Fidelity approach prioritises security certainty over operational efficiency.

The limitation is asset coverage and on-chain capability. Fidelity Digital Assets supports a more limited asset universe than Coinbase Custody or Anchorage, and its cold-storage-centric approach limits staking and DeFi interaction capabilities. For institutions seeking pure Bitcoin and Ethereum custody with Fidelity’s brand assurance, it is a strong option. For institutions needing multi-asset support with protocol interaction, alternatives are more suitable.

BitGo: The Original Institutional Custodian

BitGo launched in 2013 as the first institutional-grade Bitcoin multi-signature wallet service and has evolved into a full-service institutional custody, prime brokerage, and digital asset banking platform. BitGo holds trust charters in South Dakota and New York, and is regulated as a qualified custodian under various state frameworks.

BitGo’s technical innovation legacy is significant — it pioneered the use of multi-signature custody for institutional clients and developed the open-source standards that many custodians subsequently adopted. Its Winklevoss Custody (now Gemini Custody) and other competitors built on BitGo’s foundational work. BitGo’s current offering includes MPC custody alongside its legacy multi-sig infrastructure, prime brokerage (through BitGo Prime), and the BitGo Trust Company qualified custodian vehicle.

Strategic uncertainty has periodically surrounded BitGo. The failed Goldman Sachs acquisition in 2022 and subsequent SPAC process were resolved with an independent path forward, but the episodic ownership uncertainty has affected business development. BitGo remains a credible choice for institutional custody, particularly for clients who value the depth of its technical infrastructure and the established track record of its trust charters.

Anchorage Digital: Crypto-Native Banking

Anchorage Digital is the only federally chartered crypto bank in the United States, holding a national bank charter from the OCC (Office of the Comptroller of the Currency) since January 2021. This charter — the most robust banking regulatory status available in the US federal system — provides Anchorage with regulatory standing that Coinbase Custody’s state trust charter does not fully match.

Anchorage’s on-chain capability is a competitive differentiator. Its MPC-based custody infrastructure is designed to interact with blockchain protocols natively — staking, governance participation, DeFi protocol interaction, and cross-chain messaging are all supported within the custody environment. For institutional clients seeking active on-chain participation alongside custody, Anchorage’s technical architecture is among the most advanced available.

Anchorage’s limitation is scale: its AuC is substantially smaller than Coinbase Custody or Fidelity Digital Assets, and its client base is more concentrated in crypto-native institutions (crypto VCs, blockchain protocol foundations, crypto funds) than in traditional asset management. This concentration limits its relevance for mainstream institutional allocators seeking broad multi-asset custody at scale.

Copper Technologies: The Prime Brokerage Innovator

Copper Technologies, founded in 2018 and with significant Swiss operations, has distinguished itself through the ClearLoop network — a settlement and custody solution that solves one of institutional crypto trading’s most persistent risk problems. ClearLoop allows institutional clients to trade on crypto exchanges without depositing assets with the exchange. Assets remain in Copper’s custody; ClearLoop facilitates real-time settlement between Copper (as custodian) and exchange accounts. The counterparty risk of exchange failure is effectively eliminated.

For institutional traders — hedge funds, prop desks, asset managers — ClearLoop’s risk profile improvement is substantial. The FTX collapse demonstrated precisely the risk that ClearLoop is designed to eliminate: exchange custody of client assets in an entity that subsequently fails. Copper clients with assets in ClearLoop in November 2022 were not exposed to the FTX failure in the way that exchange-custody clients were.

Copper’s Swiss entity is FINMA-registered, providing regulatory standing in Switzerland. The company’s UK regulatory history is more complex: Copper withdrew its FCA cryptoasset registration application in 2023 and subsequently reapplied, a process reflecting the FCA’s demanding standards rather than any specific Copper compliance failure. The Swiss entity has been the more stable regulatory anchor.

Hex Trust: The Asian Institutional Custodian

Hex Trust, headquartered in Hong Kong with operations across Asia, has built the most prominent institutional-grade custody offering in the Asian time zone. Licensed by the Hong Kong SFC and regulated under the HKMA’s stored value facility framework for relevant services, Hex Trust provides custody and prime services primarily to Asian institutional clients and blockchain projects.

Hex Trust’s relevance for this comparison is primarily as a benchmark for Swiss custodians seeking Asian institutional mandates: Hex Trust represents the alternative that Asian institutional clients may consider against Swiss custodians. Its asset coverage and regulatory standing in Hong Kong are strong; its on-chain capabilities and DeFi support are among the most advanced of any regulated custodian.

Swiss Custodians in Global Context

AMINA Bank

AMINA Bank (formerly SEBA Bank) holds a full Swiss banking licence, subjecting it to FINMA supervision at the same level as UBS or Credit Suisse. Its custody infrastructure combines HSM and MPC technology, with particular strength in structured product custody — AMINA has been an active participant in the Swiss Bitcoin ETP market, providing custody services for ETP issuers.

AMINA’s full banking licence provides depositor protection for fiat holdings and, via the DLT Act, statutory insolvency protection for digital asset custody. Its capital adequacy requirements under FINMA’s banking supervision exceed those of any US trust charter custodian.

Sygnum Bank

Sygnum holds the same dual licence — banking plus securities dealer — as AMINA, with particular strength in tokenisation infrastructure through its Desygnate platform. Sygnum custody clients benefit from integrated access to Sygnum’s tokenised asset marketplace, staking services, and lending products within a single banking relationship.

Taurus Group

Taurus operates as B2B infrastructure rather than a direct custodian to end-institutional clients. Its PROTECT platform powers the custody operations of multiple Swiss and European banks. For institutional clients whose bank runs on Taurus infrastructure, the custody quality is determined by both the bank’s regulatory standing and Taurus’s technical platform — a compound assurance. Taurus’s SIX Group investment (SIX acquired a significant stake in 2024) provides institutional credibility that few fintech-origin custody infrastructure providers can match.

8 Custodians × 10 Dimensions

The DLT Act Insolvency Protection: A Structural Differentiator

The DLT Act insolvency protection warrants extended analysis because its legal significance is frequently underappreciated in discussions dominated by technology specifications.

Under Swiss law (Article 242a SchKG), digital assets held in custody by a FINMA-supervised entity are:

1. Legally segregated from the custodian’s own assets
2. Not included in the custodian’s insolvency estate
3. Returned to clients by the insolvency administrator without clients needing to file claims as unsecured creditors

This three-part protection is unconditional and statutory — it applies regardless of what the custodian’s terms of service say, regardless of the terms of any pledge or security arrangement that has not been properly registered, and regardless of the specific circumstances of the insolvency.

In the United States, the legal position for crypto custody in insolvency remains partially unresolved. The Celsius Network bankruptcy (2022–2023) and Voyager Digital bankruptcy (2022–2023) both resulted in courts treating certain customer crypto assets as part of the bankrupt estate, subjecting customers to losses. The SEC’s Staff Accounting Bulletin 121 (since partially revised) created accounting obstacles for bank-grade crypto custody. The qualified custodian definition under the Investment Advisers Act remains under regulatory development.

For institutional investors with fiduciary obligations — pension funds, insurance companies, endowments, registered investment advisers — the difference between statutory insolvency protection and uncertain US or UK bankruptcy court outcomes is a material factor in custody due diligence. Swiss custodians can offer this protection as a legal fact rather than a contractual representation.

The Travel Rule: FINMA Implementation vs Global Standards

FINMA’s Article 47a Banking Ordinance Travel Rule implementation creates a compliance dimension for custody that differentiates Swiss custodians from US and Asian peers.

Swiss custodians must conduct VASP verification for all crypto transfers above CHF 1,000, transmit originator and beneficiary data simultaneously with transfers, and maintain documentation for unhosted wallet transfers. For institutional clients managing portfolios that include transfers to multiple counterparties, this creates compliance workflows that US custodians with FinCEN-standard Travel Rule implementation do not face in the same way.

The practical implication: Swiss custodians’ Travel Rule compliance creates friction for transfers to jurisdictions with incomplete FATF Travel Rule implementation, but creates confidence for transfers to EU, UK, and US counterparties who have their own increasingly stringent data transmission requirements. The net institutional client benefit is credibility with regulated counterparties globally.

For Institutional Investors: The Custody Selection Framework

Institutional investors evaluating custody providers should apply a structured framework:

Step 1: Jurisdictional insolvency risk. Does the custody jurisdiction provide statutory insolvency protection? Switzerland: yes. US: partially, depends on charter type and asset characterisation. UK: no equivalent statute. Hong Kong: no equivalent statute.

Step 2: Regulatory standing of custodian. Is the custodian a licensed bank, trust company, or equivalent? Swiss custodians with banking licences hold the most robust regulatory standing globally. Anchorage’s OCC charter is the closest US equivalent.

Step 3: Technology architecture. Does the custody architecture match the client’s operational requirements? High-frequency trading clients need MPC-enabled programmatic signing. Long-duration holdings benefit from cold storage HSM approaches.

Step 4: Asset coverage and on-chain capability. Does the custodian support all assets in the portfolio and any planned staking or protocol participation?

Step 5: Geography and counterparty concentration. Does the custodian’s geographic presence match the client’s investment strategy? Is counterparty concentration risk managed through dual-custodian arrangements?

For most European and Swiss institutional investors, the convergence of DLT Act insolvency protection, banking-grade regulatory standing, and established institutional client relationships makes Swiss custodians the natural anchor for digital asset custody. Global custodians — particularly Coinbase Custody and Anchorage for US clients — provide viable alternatives but cannot replicate Switzerland’s statutory legal certainty.

Donovan Vanderbilt is a contributing editor at ZUG TRADING. This comparison is based on publicly available regulatory filings, company disclosures, and industry research. Custody capabilities evolve; readers should verify current offerings directly with custodians. This article is informational and does not constitute investment, legal, or compliance advice.