Public Deposits

Accepting funds from third parties are regarded as public deposits if they are liabilities owed to clients. In case of token offerings, accepting third-party public funds are generally not regarded as public deposits to be subject to banking license, because they are usually not associated with claims for repayment on the ICO organiser.


  • liabilities with debt capital character (e.g. promises to return capital with a guaranteed return) are treated as deposits
  • stable coin offerings can give rise to licensing under the Banking Act (Banking License)

Prominent banking license relaxations (even where the Banking Act applies):

Public Deposits-image
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