Liechtenstein’s Sanctions Ordinances and the Financial Intelligence Unit (FIU)
Overview of Liechtenstein Sanctions Ordinances
The Liechtenstein Sanctions Ordinances are governed by Swiss war material, goods control, and embargo legislation applicable in Liechtenstein. This means that any sanctions-related activities or transactions within Liechtenstein must comply with these regulations.
Changes to UN Sanctions Lists
The Financial Intelligence Unit (FIU) provides information on changes to UN sanctions lists through the goAML software solution. This facilitates more efficient and secure submission of suspicious activity reports. The FIU uses this platform to disseminate updated information, ensuring that relevant parties are informed about any modifications to the sanctions lists.
Reporting of Frozen Funds and Economic Resources
The coercive measures in place provide for the freezing of funds and economic resources of natural persons, entities, and organizations. This can be identified through a simple search on the Liechtenstein legislation website, where listed names are available.
Key Points:
- Identification: The list of names is easily accessible, allowing individuals to identify if their name or that of an entity is included.
- Triggering Reporting Obligation: A reporting obligation is triggered when holding, managing, or having knowledge of funds or economic resources that must be assumed to fall under the freeze. Suspicion or suspicious facts are sufficient to give rise to this obligation.
Additional Information
- Those subject to the law must assess direct or indirect control.
- Cases from recent practice have shown that some individuals assume a report of suspicion under Article 17(1) SPG can be submitted in lieu of a report under the ISA. However, the FIU disagrees with this view and states that a report must be made immediately to the Financial Intelligence Unit under the sanctions ordinance.
By understanding the nuances of Liechtenstein’s Sanctions Ordinances and the role of the Financial Intelligence Unit, individuals and organizations can ensure compliance with relevant regulations and avoid potential penalties.