Yes they do, the Swiss law got changed so that every fx dealer needs a banking license. If it gets denied for whatever reason, they have to close down or go to a jurisdiction with less strict regulation. They are somewhat in the limbo, legally speaking, at the moment.
Note that senior management in a bank is required to pass the 'fit and proper' test. For a bank, there are additional requirements above and beyond minimum capitalization.
Before that law was passed, fx wasn't really regulated at all in Switzerland, that was the reason why a lot of not-so-sincere shops set up there in the past. As did Dukas.