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Tokenized Assets (TT) Service Providers and Cryptocurrency Mining Regulations in Liechtenstein

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This article summarizes the main points of the regulations in Liechtenstein for Tokenized Assets (TT) Service Providers and Cryptocurrency Mining.

TVTG Licenses


To operate as a TT service provider in Liechtenstein, you must obtain a TVTG license. The following are some key requirements:

  • Minimum Substance Requirements: You must have a separate office space and meet certain reliability requirements for governing body members and shareholders/owners/partners holding more than 10% of the TT service provider.
  • Technical Suitability: You must demonstrate sufficient technical qualification, which can be met by outsourcing to a qualified third party.

Additional Requirements for Specific Types of Providers


Depending on your type of TT service provider business, you may need to meet additional requirements:

  • Exchange Service Providers (Crypto Exchanges): Your minimum capital requirement depends on transaction volumes. You must also have suitable internal control mechanisms and disclose comparable market prices.
  • Token Issuers: Your minimum capital requirement depends on issuing volume per 12 months. You must prepare a BID outlining key information on the token issuance.
  • Crypto Custodians: You must have a minimum capital of CHF 100,000.

KYC/AML Requirements


To ensure compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations, you must:

  • Fulfill all KYC/AML requirements of the Due Diligence Act.
  • Put in place adequate KYC and AML policies that are approved by the FMA.
  • Store all KYC/AML data in Liechtenstein.

Other Requirements


To maintain a high level of security and integrity, you must:

  • TT Key Custodians and Token Custodians: Have measures to prevent loss of private keys/tokens, segregate safekeeping from business assets, and establish clear assignment of customer tokens.
  • Business Continuity Management: Install a program to ensure services can be maintained in the event of interruptions.

Supervision


The FMA is responsible for supervising all TT service providers under the TVTG. You are subject to:

  • Event-driven or ad hoc supervision, rather than ongoing prudential supervision like licensed financial intermediaries.
  • The FMA will monitor your activities and ensure compliance with regulations.

Please note that this summary is based on the information provided in your text and may not be exhaustive or up-to-date. It’s always best to consult with a qualified professional for the most accurate and current information.