Financial Crime World

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

A. Trusts, Company Service Providers (TCSPs), and Financial Institutions

The evaluation highlights several weaknesses in the implementation of CDD requirements by TCSPs:

  • Inaccurate information held by Liechtenstein professional trustees: There are concerns about the accuracy of information held by these professionals.
  • Insufficient inspections of TCSPs: The FMA should consider increasing the frequency of inspections of TCSPs based on risk.

While there have been improvements in transparency, there are still significant challenges in the effective implementation of the legal framework for legal persons and arrangements:

  • Inherent risks in certain types of institutions: There are elements of risk inherent in some types of institutions that can be created in Liechtenstein, such as deposited foundations and anstalten.
  • Improving transparency through supervision: The report recommends improving transparency by:
    • Strengthening supervision of TCSPs
    • Clarifying powers to obtain confidential information
    • Subjecting “deposited” foundations to the same registration requirements as “registered” foundations

23. Non-Profit Organizations

The evaluation highlights several issues with the supervision of NPOs by the FSA:

  • Lack of supervision for associations: Associations set up with a common-benefit purpose are still not subject to any form of supervision.
  • Inadequate supervision for FATF issues: The supervision of NPOs by the FSA does not adequately extend to FATF issues.
  • No measures to sanction violations: No measures are in place to sanction violations of measures applicable to NPOs.