The Swiss Federal Council has proposed a simple plan that would exempt small fintech firms (accepting less than 1 million CHF from customers – or a bit over $1 million) from the requirement to seek authorization in order to conduct business:
the acceptance of public funds up to CHF 1 million should not be classified as operating on a commercial basis and can be exempt from authorisation
This is probably the simplest “sandboxing” proposal we’ve yet come across. A clear and easy to interpret minimum-dollar threshold for when you are and are not regulated is exactly what we’ve advocated for here in the US in the context of state money transmission licensing.
Again, as with the FCA in the UK and the MAS in Singapore, foreign jurisdictions are leading the way in offering reasonable and pro-innovation policies for these new financial technologies and the small start-ups that are building them.