Liechtenstein’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Framework

Overview

• Liechtenstein does not maintain a domestic terrorist list but takes action based on foreign lists, such as the European Regulation and OFAC.
• The Liechtenstein Financial Intelligence Unit (FIU) is responsible for gathering and analyzing financial intelligence.

Law Enforcement

• Law enforcement in ML/FT cases rests with the Public Prosecutor and national police.
• Investigations are often initiated by mutual legal assistance requests and FIU reports, but there’s a trend to transfer cases to jurisdictions where the predicate offense occurred.

Preventive Measures - Financial Institutions

• AML/CFT preventive measures are defined in the Due Diligence Act (DDA) and expanded in secondary legislation (Due Diligence Ordinance - DDO).
• The DDA requires due diligence for legal and natural persons when conducting financial transactions on a professional basis.
• Liechtenstein has established an overall risk-based approach, which requires financial institutions to build and update profiles for each long-term customer.

Compliance

• Provisions regarding Customer Due Diligence (CDD) are broadly in line with international standards but need strengthening in some areas.
• Financial institutions may rely on domestic and foreign intermediaries to provide CDD information, which raises concerns about responsibility and oversight.

Supervision

• The Financial Market Authority (FMA) is an independent authority responsible for prudential and AML/CFT supervision as well as customer protection.
• The FMA has developed and implements a range of AML/CFT preventive measures, including annual on-site examinations by external auditors.