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Assessment Report on Liechtenstein’s Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) Regime

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Money Laundering

Liechtenstein’s anti-money laundering regime has been assessed to identify areas for improvement. Key findings include:

Investigation and Prosecution

  • Most money laundering investigations in Liechtenstein are triggered by incoming MLA requests from abroad.
  • Analysis of financial flows is essential for effective ML investigations.
  • There have been few ML prosecutions targeting sophisticated schemes, including those involving complex legal structures established and managed in Liechtenstein.

Tax Crimes

Tax crimes committed abroad have not been subject to an ML prosecution in Liechtenstein. This is due to the fact that:

Lack of Predicate Offense

  • Tax evasion is not considered a predicate offense, making it challenging for authorities to investigate tax-related money laundering cases.

Confiscation of Proceeds

Confiscation of proceeds of crime is pursued as a policy objective in Liechtenstein. The country has established a comprehensive legal framework and strengthened its capacity to:

Detect, Seize, Freeze, and Confiscate Assets

  • Conviction- and non-conviction-based confiscation, including equivalent value, are frequently applied in practice.

Terrorist Financing

The assessment found that there have been no TF prosecutions or convictions in Liechtenstein. Additionally:

Medium Risk of TF Identified

  • A medium risk of terrorist financing has been identified in the national TF risk assessment.
  • Authorities are equipped with skills and knowledge on detecting, collecting, moving, and using funds for TF purposes.

Other Findings

Liechtenstein’s legal framework ensures automatic implementation of UN TFS related to TF/PF into the national framework. The country has also:

Amended Legislation in Line with FATF Recommendations

  • Recently amended its legislation in line with FATF Recommendations covering TF/PF TFS-related supervision, procedures for designation, listing, and delisting.