Financial Crime World

Title: Liechtenstein’s Financial Sector Under Scrutiny: Key Findings from the MONEYVAL Report

Introduction

On June 29, 2022, the Money Valuation Committee (MONEYVAL) published its assessment report on Liechtenstein’s progress in preventing and combating money laundering (ML) and terrorism financing (TF), revealing both significant advancements and areas for improvement.

Acknowledged Progress in Liechtenstein

  • Understanding ML/TF risks
  • Setting national policies
  • Using financial intelligence
  • Confiscating proceeds of crime

Major Concerns

  1. Supervision
  2. Private sector adherence to AML/CFT preventative measures
  3. Transparency of beneficial ownership (BO)

Liechtenstein’s Financial Sector Roles in Laundering Tax Crimes and Non-bank Assets

  • Limited understanding of potential role in laundering tax crimes
  • Limited information on types and locations of trust and company service providers’ (TCSPs) non-bank assets

Exemptions in ML/TF Policies

  • Investment funds’ exemptions not based on country risk assessment

Recommendations for the FIU and strategic analysis reports

  • Further comprehensive strategic analysis reports on TF, foreign tax crimes, and SAR/STR reporting

Measures against ML and confiscation of proceeds

  • All types of ML investigated and prosecuted
  • Non-conviction-based confiscation introduced
  • Insufficiently dissuasive sanctions imposed for confiscation

TF Prosecutions

  • Lack of TF prosecutions, in line with country’s risk profile

NPOs

  • Good awareness of risks but need for greater understanding of CFT measures

Private sector’s understanding of ML/TF risks

  • Improved significantly
  • Banks, large TCSPs, and wealth management institutions
  • Effective measures
  • Requirements for “qualified members”
  • Access to basic and BO information timely and accurate but not comprehensive

International Cooperation

  • Crucial aspect of Liechtenstein’s AML/CFT efforts
  • Possible impact of double criminality requirements and obligation to hear eligible party before providing evidence
  • Recent measures to mitigate these risks