Financial Crime World

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Evaluation Report on Liechtenstein’s Anti-Money Laundering Regime

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Recommendations for Improvement

The Financial Action Task Force (FATF) has evaluated Liechtenstein’s anti-money laundering (AML) regime and identified key areas that require improvement. The following recommendations have been made to enhance the effectiveness of Liechtenstein’s AML regime:

Corporate Liability

  • Introduce corporate criminal liability to deter companies from misusing their structures for money laundering purposes.

International Instruments

  • Ratify the Vienna Convention and join the 1978 Additional Protocol to the European Convention on Mutual Legal Assistance (ECMA).
  • Reconsider the policy barring mutual legal assistance in fiscal matters, as recent practice shows few cases where assistance was denied.

Sector-Specific Guidance

  • Provide specific guidance to financial institutions on suspicious transactions and related reporting requirements.

Closure of “Old” Bearer Accounts

  • Close down or transform “old” bearer accounts (passbooks) into nominative accounts due to their transferability raising issues with FATF Recommendation 10.

Due Diligence Act Amendments

  • Amend the Due Diligence Act to explicitly prohibit bearer accounts and other financial products.

Recording of Customer Information

  • Introduce a clear legal requirement for recording customer information, including name, address, and account number, for international fund transfers.

Prohibition of Tipping Off

  • Review the Due Diligence Act to clearly prohibit and sanction tipping off customers about Suspicious Transaction Reports (STRs).

FIU Access to Information

  • Empower the Financial Intelligence Unit (FIU) to have comprehensive and direct access to relevant financial information, including beneficial ownership data.

Increased Professional Staff at FIU

  • Increase professional staff at the FIU to enhance its efficiency in fulfilling its functions.

Additional Recommendations

The evaluation team has also made additional recommendations to further strengthen Liechtenstein’s AML regime:

Law Enforcement Agencies

  • Equip law enforcement agencies with additional investigative means for conducting money laundering investigations.
  • Proactively search and trace assets involved in proceeds of crime.

Overall Assessment

The evaluation team believes that Liechtenstein’s AML regime has improved significantly since the first evaluation round, but it requires further refinement through rapid implementation of these recommendations to ensure sustainability of progress achieved.