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Liechtenstein’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Systems: An Overview

General Situation

Liechtenstein, an international financial centre with a high level of foreign involvement, has taken steps to strengthen its AML/CFT framework since its last evaluation.

• High level of foreign involvement: Liechtenstein’s financial sector is highly interconnected with the global economy.
• Strengthening AML/CFT framework: The country has implemented measures to enhance its anti-money laundering and combating terrorism financing capabilities.

Risk Assessment

The primary ML threats in Liechtenstein stem from non-resident customers who may seek to transfer criminal proceeds or use financial intermediaries for illicit activities. Economic crime, corruption, and fraud are the most relevant predicate offenses.

• Primary ML threats: Non-resident customers pose a significant risk of money laundering.
• Relevant predicate offenses: Economic crime, corruption, and fraud are the primary concerns.
• Risk of terrorism financing: The threat of funds being used for terrorism is low, but the risk that Liechtenstein may be misused for TF purposes is medium.

Understanding and Identification of Risk

Most persons subject to the DDA have a limited understanding of identifying persons indirectly controlling or owning funds involved in transactions. While basic information on legal persons and arrangements is available from registers maintained by the Office of Justice, BO information may not always be accurate and up-to-date.

• Limited understanding of risk identification: Most individuals subject to the DDA lack sufficient knowledge.
• Availability of information: Basic information is available from public registers, but its accuracy and timeliness are uncertain.

International Cooperation

Liechtenstein has a comprehensive framework for international cooperation with foreign jurisdictions, including formal and informal channels. However, some issues related to dual criminality requirements regarding tax evasion could impact effective cooperation.

• Comprehensive framework: Liechtenstein has established robust mechanisms for international cooperation.
• Potential challenges: Dual criminality requirements may hinder cooperation in certain cases.

Compliance and Effectiveness

In most respects, the elements of an effective AML/CFT system are in place. However, the practical application of existing frameworks needs improvement. The jurisdiction has strengthened its legal and regulatory framework since its last evaluation and conducted comprehensive NRAs.

• Effective system: The foundation for a robust AML/CFT system is established.
• Room for improvement: Practical implementation requires refinement to ensure effectiveness.

Conclusion

Liechtenstein’s AML/CFT system is considered to be in a good position, with some areas requiring improvement.