Financial Institutions and Businesses Face Tough Anti-Money Laundering Requirements

Liechtenstein has introduced stringent anti-money laundering (AML) requirements for various financial institutions and non-financial businesses to combat financial crimes. The measures aim to prevent the misuse of financial systems for illegal activities such as money laundering, terrorist financing, and organized crime.

Entities Subject to AML Requirements

The following entities are subject to AML requirements:

Financial Institutions: Banks and investment firms
E-Money Businesses: E-money businesses
Collective Investment Undertakings: Undertakings for collective investment that market their unit certificates or units
Insurance Companies: Insurance undertakings
Exchange Offices: Exchange offices, including Trustworthy Technology (TT) exchange service providers
Financial Service Providers: Insurance brokers, payment service providers, asset management companies, and providers of certain services for legal entities
Online Gaming Operators: Casinos and online gaming operators
Professionals: Lawyers and law firms providing tax advice or assisting in financial transactions, members of tax consultancy professions and external bookkeepers, real estate agents
Goods Traders: Persons trading goods, including those using cryptocurrencies, with transaction values exceeding CHF 10,000
TT Service Providers: TT service providers, such as token issuers, depositaries, exchange service providers, and others
Trading Platform Operators: Operators of trading platforms for non-fungible tokens
Art Dealers: Art dealers, where the value of transactions exceeds CHF 10,000
Custodians and Rentiers: Custodians of third-party assets and rentiers of safe custody facilities

AML Requirements

Entities subject to AML requirements must implement a risk-based approach, which includes:

Identification and Verification

Identifying and verifying the identity of contracting parties, beneficial owners, and recipients of distributions
Establishing a business profile and monitoring transactions

Business Relationship Supervision

Supervising business relationships in line with the level of risk involved

Monitoring and Investigation

Entities must conduct timely and adequate monitoring of their business relationships, including transactions processed during the relationship. They must be vigilant for changes in customer behavior or deviations from typical patterns, and carry out simple investigations when necessary.

Special Investigations

Special investigations are required when there is suspicion that assets are connected to money laundering, predicate offenses, organized crime, or terrorism.

Objectives of AML Requirements

The introduction of these AML requirements aims to:

Strengthen financial stability
Prevent financial crimes
Ensure the integrity of Liechtenstein’s financial system