Financial Crime World

Anti-Money Laundering Requirements in Liechtenstein

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Covered Entities

The following financial institutions and non-financial businesses and professions are subject to anti-money laundering (AML) requirements in Liechtenstein:

1. Banks and Investment Firms

  • These institutions must comply with AML requirements to prevent the use of their services for money laundering activities.

2. E-Money Businesses

  • Electronic money issuers, e-wallet providers, and other digital payment service providers must implement AML measures to combat money laundering.
  • Examples:
    • Mobile payment apps
    • Online wallets
    • Digital payment processors

3. Undertakings for Collective Investment

  • Companies that market unit certificates or units must comply with AML regulations to prevent the use of their services for illicit activities.

4. Insurance Undertakings

  • Insurance companies, including life insurance and non-life insurance providers, must implement AML measures to detect and prevent money laundering.
  • Examples:
    • Life insurance policies
    • Health insurance plans
    • Property and casualty insurance

5. Exchange Offices

  • Exchange service providers, including those offering currency exchange services, must comply with AML requirements to prevent the use of their services for money laundering activities.

6. Insurance Brokers

  • Insurance intermediaries must also implement AML measures to combat money laundering in the insurance sector.

7. Payment Service Providers

  • Payment institutions, such as e-wallet providers and digital payment processors, must comply with AML regulations to prevent money laundering.
  • Examples:
    • Credit card processing companies
    • Digital banking platforms
    • Online payment gateways

8. Asset Management Companies

  • Companies managing assets for clients must implement AML measures to detect and prevent money laundering activities.

9. Lawyers and Law Firms

  • Law firms that provide tax advice or assist in the planning and execution of financial transactions must comply with AML requirements.
  • Examples:
    • Tax consulting services
    • Financial transaction planning

10. Tax Consultancy Professions and External Bookkeepers

  • Professionals who offer tax consulting services or act as external bookkeepers for clients must implement AML measures to prevent money laundering.

11. Real Estate Agents

  • Real estate agents must also comply with AML regulations, particularly when dealing with high-value transactions involving cash or crypto-assets.
  • Examples:
    • Luxury property sales
    • Commercial real estate transactions

12. Cryptocurrency Service Providers

  • Companies offering cryptocurrency exchange services, trading platforms, and other crypto-asset related services are subject to AML requirements in Liechtenstein.

Covered Payments or Money Transmission Activities

The following types of payments or money transmission activities are subject to anti-money laundering requirements:

1. Cash Transactions

  • Transactions exceeding CHF 10,000, regardless of whether they involve a single operation or multiple connected operations.
  • Examples:
    • Large cash withdrawals from ATMs
    • High-value cash deposits into bank accounts

2. Crypto-Asset Transactions

  • Transactions involving cryptocurrencies, tokens, or other digital assets, including exchanges between fiat currencies and crypto-assets.
  • Examples:
    • Buying or selling cryptocurrencies on online exchanges
    • Using cryptocurrencies to purchase goods or services

3. E-Money Transactions

  • Electronic money transfers, payments, or conversions.

Exceptions

Exceptions to these requirements may apply in certain cases:

1. Low-Risk Transactions

  • Small-value transactions that do not pose a significant risk of money laundering.
  • Examples:
    • Everyday purchases using debit cards
    • Small cash withdrawals from ATMs

2. Business Relationships with Low-Risk Customers

  • Customers who have been thoroughly vetted and assessed to be low-risk for money laundering activities.
  • Examples:
    • Long-standing business relationships with established clients
    • Regular customers with a proven track record of legitimate transactions