--- title: "Liechtenstein (LI) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/liechtenstein/ source_html: /jurisdictions/liechtenstein/index.html description: "Financial integrity intelligence for Liechtenstein (LI): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: fe96e28a1e8816b621096745adb1605f8d65529f0621497d6c7e41a5128aa232 generator: "fe-fleet/md-twin@1.0" --- # Liechtenstein (LI) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Liechtenstein LI Domains covered 8 of 8 Sources 155 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Liechtenstein is a MONEYVAL-assessed EEA/EFTA state (not an EU member) whose Due Diligence Act and Financial Market Authority (FMA) govern AML/CFT for banks, TCSPs, foundations/Anstalten and VASPs under the bespoke Blockchain Act (TVTG). More It autonomously aligns its national sanctions ordinance with EU CFSP measures rather than being bound as an EU member. Key deficiencies - FMA sanctions against breaches are not demonstrably proportionate or dissuasive; TCSP-sector enforcement is particularly weak (MONEYVAL 2022) - Simplified due-diligence exemption for investment funds not supported by a documented risk assessment despite extensive use - ML sanctions imposed by Liechtenstein courts assessed as not proportionate and dissuasive - Low volume/level of monetary fines relative to financial-centre size and international clientele risk profile Recent developments (18m) - Liechtenstein FIU connected to the EU's 'Next-Generation' FIU.net (3 Feb 2025), expanding the network to 30 FIUs - OFAC's March 2026 Sham Transactions and Sanctions Evasion advisory cites the Potanin/Sentimare Liechtenstein foundation-concealment case as a lead typology example - Ongoing Liechtenstein prosecutorial investigation into suspected insolvency fraud and money laundering tied to the Signa/Benko collapse, involving Liechtenstein legal structures - Repeated 2025 EU Council Decision alignments by Liechtenstein on Russia sanctions packages (July, Aug, Sept, Oct, Nov, Dec 2025) - Ongoing revision of the Liechtenstein Blockchain Act (TVTG) to align with the EU's MiCA regime Law made at European Economic Area level that applies in Liechtenstein is covered once, on the [European Economic Area](/jurisdictions/eea/) page. This page covers Liechtenstein’s own layer: implementation, national authorities, national options and local enforcement. Brief ## Lead signal #### Lead Signal Liechtensteins Register of Beneficial Owners, the VwbP, was breached overnight on 29-30 July 2026, with an unknown perpetrator gaining unauthorised digital access and exfiltrating data on roughly 31,000 legal entities, including companies, foundations and trusts. The government has stated there is no evidence of alteration or deletion of the underlying data, and the banking sector was not affected by the intrusion. The breach does not appear to be contested across the reporting that has emerged on it, and it lands squarely on the instrument that exists to give authorities and obliged entities a reliable, centralised view of who stands behind Liechtensteins legal persons and arrangements, a sector long associated internationally with layered trust and foundation structures. Read full brief #### Lead Signal Liechtensteins Register of Beneficial Owners, the VwbP, was breached overnight on 29-30 July 2026, with an unknown perpetrator gaining unauthorised digital access and exfiltrating data on roughly 31,000 legal entities, including companies, foundations and trusts. The government has stated there is no evidence of alteration or deletion of the underlying data, and the banking sector was not affected by the intrusion. The breach does not appear to be contested across the reporting that has emerged on it, and it lands squarely on the instrument that exists to give authorities and obliged entities a reliable, centralised view of who stands behind Liechtensteins legal persons and arrangements, a sector long associated internationally with layered trust and foundation structures. The significance of the incident is structural rather than purely episodic. A beneficial-ownership register is only as useful as the trust placed in its integrity and confidentiality, and the fact that some 31,000 entities worth of data moved outside the perimeter means that, irrespective of whether the register itself was altered, confidence in the safeguarding of sensitive ownership data has been tested in a way that outlasts the immediate incident. #### Other Developments A new national Anti-Money Laundering Act is moving through consultation. The government adopted a consultation report on 3 March 2026 for a national Anti-Money Laundering Act, intended to transpose the sixth EU Anti-Money Laundering Directive and to repeal the existing Due Diligence Act (SPG). The directly-applicable EU AML Regulation will take over the substantive customer-due-diligence content currently sitting in the SPG once it is incorporated into the EEA Agreement. A working target date of 10 July 2027 has been cited for both the Regulations direct application and the new Acts entry into force, though that date rests on commentary rather than on a primary government confirmation, and it remains contingent on EEA Joint Committee incorporation. The underlying architecture is that AML supervision and rulemaking in the European Economic Area is moving from a purely national-text model toward a structure built on three distinct instruments: a directly-applicable Regulation carrying the single rulebook of due-diligence content, a Directive transposed country by country covering institutional and supervisory-cooperation matters, and a dedicated Regulation establishing a new EU-level Anti-Money Laundering Authority with direct and indirect supervisory reach over certain obliged entities. For Liechtenstein, as for other European Economic Area states, this shifts AML oversight from a wholly national authority model toward one with an EU-level supervisory layer sitting above it. Liechtensteins standing AML/CTF posture remains favourable on the metric that matters most internationally. The Council of Europes MONEYVAL mechanism placed Liechtenstein on its regular, non-enhanced follow-up track following its 2022 mutual evaluation, one of only five jurisdictions evaluated to receive that result, with the next onsite evaluation not due until 2030. The evaluation did flag that further improvements were needed in supervision, private-sector application of preventative measures, and beneficial-ownership transparency specifically, which gives the current register breach an unwelcome resonance with a pre-existing, identified area of concern rather than introducing an entirely new one. Enforcement activity against Due Diligence Act breaches continued at a steady pace. The Financial Market Authoritys most recent annual report recorded CHF 590,000 in fines that became legally binding across 17 separate proceedings, of which 13 concerned violations of the Due Diligence Act. This is consistent with an active, functioning supervisory enforcement pipeline operating under the existing legal framework, ahead of its planned replacement. #### Cross-Monitor Connections The VwbP breach sits at the intersection of beneficial-ownership transparency and compliance-technology resilience: the same centralised registry infrastructure that the European due-diligence architecture increasingly relies on as a single source of truth for ownership data is also, by virtue of that centralisation, a concentrated target. A failure of confidentiality in that infrastructure has implications beyond Liechtenstein for any jurisdiction leaning on similarly centralised registers as the backbone of its transparency regime. Separately, the TVTG-to-MiCA licensing transition that closed on 1-2 July 2026, converting Liechtensteins pre-MiCA token regime into the EU-wide Markets in Crypto-Assets framework, intersects with the AML/CTF regime insofar as crypto-asset service providers operating in or from Liechtenstein remain subject to the same due-diligence obligations now being restructured under the pending AML Regulation and Act, once those instruments take effect. #### Outlook The immediate test for Liechtenstein is whether the governments response to the register breach, strengthening the VwbPs technical safeguards, demonstrates the kind of institutional resilience that MONEYVAL evaluators will weigh favourably when the next onsite assessment occurs around 2030, rather than becoming a standing vulnerability narrative attached to the countrys beneficial-ownership regime in the interim. On the legislative track, the national Anti-Money Laundering Act and the directly-applicable EU AML Regulation remain in consultation and pre-incorporation stages respectively; as scheduled, both are working toward a target date of 10 July 2027, but that date is not yet confirmed against a primary government source and is formally contingent on an EEA Joint Committee incorporation decision that has not yet been confirmed for Liechtenstein specifically. Until that incorporation step occurs, Liechtensteins obliged entities continue to operate under the existing Due Diligence Act text even as the new architecture is finalised around them. Earlier periodic briefs (4) 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Liechtenstein's financial-integrity picture this period is defined by the TGI AG matter: a Vaduz-based gold dealer ordered by the FMA on 26 May 2026 to immediately cease distributing three deposit-like products marketed as 'Customer Basic 2%', 'Sales Premium' and 'Sofortrabatt', with the order partially upheld by the FMA Appeals Commission on 12 August 2026. Liechtenstein prosecutors are investigating suspected fraud and money laundering following a June 2026 office raid on TGI AG's Vaduz premises. TGI AG is reported to have ceased its Liechtenstein operations on 31 July 2026 and relaunched as Trust Gold International Ltd in Mauritius, a cross-border continuation of the scheme following domestic enforcement. #### Other Developments The FMA has also moved against a clone entity impersonating a genuine registered firm. On 8 October 2026, the FMA published a warning against the website financial-partner-ltd.com, which unlawfully uses the identity of the genuine, registered Financial Partners FP Ltd of Vaduz, without any FMA authorisation or registration of its own. The EU AML Package continues its gradual rollout. The EU Anti-Money Laundering Authority published final drafts of three regulatory technical standards on 1 October 2026, while Liechtenstein's own implementing Anti-Money Laundering Act, replacing the SPG and transposing the 6th AML Directive, had its consultation report adopted on 3 March 2026 but remains pending incorporation by the EEA Joint Committee; the directly-applicable EU AML Regulation is due to apply from 10 July 2027. Liechtenstein's crypto-asset supervision saw a routine individual deregistration. Copper Markets voluntarily waived its registration as a VT custodian under the TVTG, effective 24 September 2026, with the registration expiring under TVTG Art. 20(1)(a), as announced by the FMA on 14 October 2026. #### Cross-Monitor Connections The TGI AG matter connects to the data-protection monitor's coverage of the same entity, which is separately reported to have notified the Datenschutzstelle of a personal-data breach and to be the subject of a DSS ex officio investigation running concurrently with the FMA's conduct enforcement and the criminal fraud and money-laundering probe. The Copper Markets TVTG deregistration connects to the crypto and world-payments monitors' coverage of the same event as a routine marker of the completed MiCAR/TVTG transitional period. #### Outlook The principal items to watch are whether the Liechtenstein prosecution of TGI AG produces a formal charge or indictment, and whether Trust Gold International Ltd's Mauritius relaunch draws any cross-border regulatory response. On the architecture side, the commencement date of Liechtenstein's national Anti-Money Laundering Act remains contingent on EEA Joint Committee incorporation, with the directly-applicable AMLR due from 10 July 2027; neither has a confirmed date yet. Liechtenstein's MONEYVAL standing remains unaffected, with the jurisdiction on the regular follow-up track since its clean 2022 report and no further evaluation scheduled until 2029-2030. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Liechtensteins central beneficial-ownership infrastructure has been operating in a degraded state since a cyberattack on 29 and 30 July 2026 compromised the Register of Beneficial Owners (VwbP), exfiltrating copies of data tied to roughly 31,000 legal entities. External access was suspended entirely in the immediate aftermath and, as of 5 October 2026, has resumed only in a restricted form: users must physically attend the Giessen Service Centre in Vaduz and identify themselves with a passport or identity card, after which a reduced range of technical functions becomes available. Statutory deadlines that cannot be met because of this limited availability have been suspended by the government. This is a material operational disruption to the transparency infrastructure that underpins Liechtensteins beneficial-ownership regime, and it lands on a jurisdiction that MONEYVAL has otherwise been tracking favourably: FATFs consolidated country materials show several Recommendations bearing on legal-person and legal-arrangement transparency upgraded from Partially Compliant to Largely Compliant, and others to Compliant. The juxtaposition is notable in architecture-over-incident terms -- a legal framework assessed as improving collides with an operational-resilience failure in the very system that framework depends on to be checked. The disruption is not confined to the register itself. Because the VwbP is also the dataset competent authorities and obliged entities rely on for ownership verification, a single cybersecurity failure now has consequences across record-keeping obligations for a wide population of legal entities and fund structures, without any change to the underlying statute, the Act on the Register of the Beneficial Owners of Legal Entities, which remains in force as adopted in 2021. #### Other Developments MiCA authorisation wave confirms Liechtensteins gateway role. Three Swiss-linked crypto firms -- RuleMatch Europe AG, Bitcoin Suisse (Europe) AG and Sygnum Europe AG -- obtained MiCA CASP authorisation from Liechtensteins FMA in June 2026, continuing a pattern in which Vaduz subsidiaries are used to access the EEA single market under the Markets in Crypto-Assets Regulation. This sits alongside the scheduled expiry of transitional registrations issued under the Token and Trusted Technology Service Provider Act for MiCAR-scoped activities, which closed in early July 2026. The commercial pattern -- Swiss-domiciled firms establishing Liechtenstein entities specifically to obtain EEA passporting -- is a structural feature of the jurisdictions business model as much as a one-off event, and is worth tracking for its implications on supervisory capacity at the FMA as authorisation volume increases. FMA enforcement against unauthorised deposit-taking continues. The FMA ordered TGI AG to cease distribution of gold-purchase-linked products and to stop taking deposits without authorisation; an Appeals Commission ruling in August 2026 partially upheld relief sought by the firm on the suspensive effect of that order. This is a conventional supervisory enforcement action against unlicensed financial activity rather than a structural development, but it demonstrates that the FMA continues to act against unauthorised conduct even as its authorisation workload from the MiCA transition has grown. #### Cross-Monitor Connections The VwbP breach is simultaneously a data-protection event: the Liechtenstein government has stated that the attack constitutes a personal data breach within the meaning of Article 33 GDPR, triggering notification obligations to the roughly 31,000 affected legal entities and, in turn, to their beneficial owners under Article 34. Readers tracking the data-protection monitor should treat this as the same underlying incident viewed through a different obligation set -- the AML transparency register and the GDPR-regulated dataset are, in this case, one and the same system. On the digital-asset side, the MiCA authorisation wave and the closure of the TVTG transitional bridge are relevant to monitoring of crypto-asset service provider licensing activity across the EEA, where Liechtenstein continues to function as an access point for Swiss-domiciled firms. #### Outlook The near-term question for Liechtensteins beneficial-ownership regime is how quickly full remote access to the VwbP can be restored without reopening the vulnerabilities that were exploited, and whether the in-person-only interim arrangement becomes a durable operational constraint rather than a short bridge. As scheduled, the government has signalled that fuller functionality will follow remediation of identified vulnerabilities, though no firm date for full restoration has been confirmed. On the crypto side, the FMA's authorisation throughput this cycle suggests the MiCA transition is substantively complete for the first wave of applicants, and subsequent cycles may show whether supervisory capacity keeps pace with a growing population of Vaduz-domiciled CASPs. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Liechtenstein's crypto-asset regime completed a structural transition this cycle: TVTG-registered TT service providers holding transitional registrations for MiCAR-covered activities saw those transitional registrations expire on 2 July 2026, moving affected firms fully onto MiCAR authorisation as applied domestically since the EEA MiCA Implementation Act (EWR-MiCA-DG) took effect on 1 February 2025. This is an architectural shift in how digital-asset activity is supervised in Liechtenstein rather than a single incident, and it is the most consequential development in the jurisdiction this cycle. Set against this, a single T3 press source reports that US sanctions enforcement has effectively frozen a number of Liechtenstein-domiciled trust structures holding Russian-linked wealth; this remains unconfirmed against any primary OFAC or OFSI designation instrument naming specific Liechtenstein entities, and should be read as a probable, not confirmed, exposure signal. #### Other Developments Liechtenstein's sanctions posture continues to rest on a mirroring rather than autonomous model. As an EEA state, Liechtenstein maintains no autonomous sanctions list of its own; it implements United Nations Security Council sanctions as a binding legal obligation and voluntarily aligns with European Union autonomous sanctions measures. This structural choice is durable and has not changed this cycle, but it is the backdrop against which the reported US sanctions pressure on Liechtenstein-domiciled trust vehicles should be read: Liechtenstein's own sanctions architecture does not itself generate an autonomous designation against Russian-linked wealth holders, and any freezing effect reported this cycle derives from US extraterritorial enforcement rather than a Liechtenstein-originated measure. The enabler-jurisdiction question turns on trust and company-service-provider supervision. Liechtenstein was rated compliant or largely compliant on 37 of 40 FATF Recommendations in its 2022 MONEYVAL mutual evaluation and placed on MONEYVAL's regular, non-enhanced follow-up track, an outcome achieved by only a small number of jurisdictions globally. Within that generally strong rating, MONEYVAL flagged beneficial-ownership transparency and trust/company-service-provider supervision as areas warranting continued improvement, a nuance that sits alongside, and partially explains, why a jurisdiction with a strong formal AML rating can still be named in reporting about opaque wealth-holding structures. #### Cross-Monitor Connections The TVTG-to-MiCAR transition and the reported US sanctions pressure on Liechtenstein trust structures both connect directly to the crypto and world-payments monitors' own coverage of Liechtenstein this cycle: the crypto monitor addresses the licensing and classification consequences of the same MiCAR transition from a digital-asset-regulation lens, while any correspondent-banking or payment-flow consequences of sanctions-related account freezes would fall within world-payments' scope should further evidence emerge. The enabler-jurisdiction signal around trust and company-service-provider opacity is also directly relevant to beneficial-ownership and corporate-transparency analysis, though that domain carried no material change of its own this cycle. #### Outlook The test for Liechtenstein's sanctions exposure going forward is whether a primary-source OFAC or OFSI designation instrument naming specific Liechtenstein entities or trust structures emerges to corroborate the current T3-only reporting; absent that, the finding should remain at probable confidence. On the enabler-jurisdiction question, the relevant marker to watch is any published follow-up assessment or supervisory action from MONEYVAL or the Liechtenstein FMA specifically addressing trust and company-service-provider oversight, which would indicate whether the flagged improvement area is being substantively addressed. 5 Sep 2026 · fim-2026-08-21 #### Lead Signal Liechtenstein's Register of Beneficial Owners (VwbP) was breached over the night of 29-30 July 2026, with unknown attackers accessing and copying data covering approximately 31,000 legal entities. The government confirmed the breach on 3 August 2026, and the Prime Minister confirmed on 13 August 2026 that no ransom will be paid, while officials continue to evaluate possible scenarios. The incident is assessed, not confirmed, on Tier-3 reporting, but its significance is structural rather than incidental: it lands on the same beneficial-ownership register that MONEYVAL's October 2025 follow-up had already flagged for completeness gaps, compounding a pre-existing transparency weakness with an active compromise of the underlying data. The breach also arrives amid a broader EEA-wide tightening of beneficial-ownership expectations under the incoming AMLR framework, sharpening the contrast between where Liechtenstein's transparency infrastructure currently stands and where the EU single rulebook will eventually require it to stand. For a jurisdiction whose favourable MONEYVAL standing rests substantially on the credibility of its beneficial-ownership infrastructure, a breach of this scale is the most consequential financial-integrity architecture event of the cycle, regardless of whether further attribution or scale confirmation follows. #### Other Developments Liechtenstein's national AMLA-implementation consultation report , adopted 3 March 2026, expands Obliged Entity scope to crowdfunding providers and intermediaries, a structural broadening of the Due Diligence Act (SPG) perimeter ahead of the EU's AMLA architecture reaching Liechtenstein. The consultation sits inside a wider EEA incorporation lag: the AMLA Regulation (Reg (EU) 2024/1620) remains under EEA Joint Committee scrutiny and is not yet applicable in Liechtenstein, while the directly-applicable AMLR Single Rulebook (Reg (EU) 2024/1624) carries a July 2027 EU/EEA-wide application date. Liechtenstein remains on MONEYVAL's favourable regular follow-up-reporting track, a status established at its 5th-round Mutual Evaluation Report in June 2022 and reaffirmed at the October 2025 follow-up — the same follow-up that flagged the beneficial-ownership completeness gaps now compounded by the breach. TVTG-registered virtual-asset service providers face an approaching transitional cut-off, with policy discussion pointing to 30 June or 1 July 2026, after which continued operation requires a complete MiCAR CASP application rather than reliance on the prior national TVTG registration. This transition layers onto existing FMA AML/CFT supervision at a moment when the OECD's Crypto-Asset Reporting Framework is also moving toward first reporting deadlines in 2026, adding cross-border tax-transparency obligations on top of the AML/CFT perimeter for the same population of supervised entities. #### Cross-Monitor Connections The beneficial-ownership breach carries a direct read-across to gambling-sector regulatory monitoring: Liechtenstein's licensed casino sector operates within the same small financial centre whose transparency infrastructure has just been compromised, and reputational-adjacency questions for licensed operators follow from the same underlying event even though the breach sits outside the gambling licensing perimeter narrowly defined. On the payments side, Liechtenstein's consolidation of its banking and payment-institution licensing architecture under the new Banking Act (BankG) intersects with the AML/CFT obliged-entity population now being expanded by the national AMLA-implementation consultation, meaning newly captured firm types will face both a reorganised licensing regime and a broadening compliance perimeter concurrently. On the digital-asset side, the TVTG-to-MiCAR transitional cut-off is the same event that Liechtenstein's crypto-regulatory monitoring is tracking from a licensing-continuity angle; from a financial-integrity angle, the same transition matters because it is the point at which AML/CFT supervision of these entities formally shifts from a national TVTG basis to the MiCAR/AMLR-aligned supervisory architecture. #### Outlook The immediate question for the next cycle is whether the Register of Beneficial Owners breach produces a confirmed attribution, a quantified final scope, or any supervisory response beyond the government's ransom refusal. A Tier-1 government-portal source has not yet been directly retrieved to corroborate the approximately 31,000-entity figure, and this gap should close before the scale of the incident is treated as settled. On the structural side, the AMLA Regulation's EEA Joint Committee incorporation for Liechtenstein remains the durable item to track: once incorporated, it will begin displacing parts of the SPG regime with directly-applicable EU supervisory architecture, a transition that will unfold over quarters rather than weeks. The 30 June/1 July 2026 MiCAR grandfathering cut-off for TVTG-registered providers is the nearer-term marker, with confirmation of the exact date still pending against only Tier-3 sourcing. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The most consequential sanctions-architecture signal this cycle is institutional reinforcement rather than fresh designation. The March 2026 OFAC advisory on sham transactions and sanctions evasion cites the June 2024 designation of four Liechtenstein-based foundations, and their Cyprus predecessor Sentimare, as a lead worked example of concealed continuing beneficial ownership. Vladimir Potanin transferred ownership of Sentimare to four Liechtenstein foundations, each structured with a single beneficiary drawn from one of four minor children, following his own sanctions designation exposure. The advisory reaffirms that all four foundations and Sentimare remain designated and blocked, and it sets forward-looking compliance expectations for foreign fiduciaries handling Liechtenstein-domiciled vehicles. Read as architecture rather than incident, the significance is not that OFAC designated four entities in 2024 but that Treasury judged the underlying concealment mechanism generalizable enough, nearly two years later, to codify into sector-wide guidance: the foundation vehicle itself, not the sanctioned individual alone, is now the object of standing regulatory attention. Continue reading The sanctions posture of Liechtenstein itself compounds this exposure. As an EEA and EFTA state without a Council vote, Liechtenstein has no automatic mechanism for adopting EU restrictive measures; instead, it repeatedly aligned its national sanctions ordinance with successive 2025 EU Russia-related packages, including the May, July, August, September, October, November and December tranches, and with the December 2025 human-rights restrictive-measures regime, entirely on a voluntary, rolling basis. This is a structural discretion and timing gap rather than an accident of drafting: each alignment decision is a discrete national policy act, meaning there is always a window, however brief, in which the Liechtenstein list has not yet caught up with the EU list. That gap sits alongside a wholly separate track of exposure, since Liechtenstein-resident entities can be designated directly by OFAC under its own jurisdiction-based authority irrespective of any EU or Liechtenstein-national listing, as the Potanin foundations themselves demonstrate. The consequence for Liechtenstein-based fiduciaries is a three-track designation-tracking burden: the EU-aligned national list, the OFAC SDN list, and the UK OFSI list must each be monitored separately given differing legal triggers and timing. Notably, no UK OFSI designation naming a Liechtenstein-domiciled entity has been identified within the eighteen-month baseline window examined this cycle, an asymmetry that may simply reflect UK enforcement priorities to date but is worth monitoring closely for a first such action, since it would mark the point at which all three major designation regimes have independently reached into the foundation and Anstalt sector of the jurisdiction. The baseline sanctions classification of Liechtenstein remains formally favourable: absent from the EU high-risk third country list per Delegated Regulations (EU) 2026/46 and 2026/83, and absent from both FATF grey and black lists as of the June 2026 plenary, monitored instead through the MONEYVAL standard post-MER follow-up track. This formal standing sits at some distance from the forensic picture surfaced by OFAC casework: a Tier 1 clean bill of jurisdictional health coexists with a Tier 1 institutional finding that a jurisdiction-specific concealment architecture required a full advisory to address. Both facts are accurate simultaneously, and the gap between them is itself a signal that formal list status is a lagging indicator of casework-level exposure in a small, high-net-worth-oriented financial centre such as Liechtenstein. #### Outlook Liechtenstein manages its absence from formal EU sanctions-setting authority through rolling autonomous alignment, a mechanism that is durable and reasonably well-tested but structurally incapable of closing the discretionary timing gap it creates, and this pattern is unlikely to be resolved absent an EU or EEA institutional change extending Liechtenstein a formal role in sanctions design. Reinforcement of the Potanin case by the OFAC advisory suggests continued Treasury attention to the Liechtenstein foundation sector specifically as a sham-transaction typology, raising the near-term probability of further guidance or enforcement activity referencing Liechtenstein-domiciled vehicles, whether or not any new underlying designation occurs. Absent an inaugural UK OFSI action naming a Liechtenstein entity, the three-track divergence pattern remains a monitored rather than a realized risk, but the structural conditions that would produce one, an EEA and EFTA state operating outside the Council vote and outside UK designation history to date, persist unchanged. #### Beneficial Ownership and Corporate Transparency Globally, the European Union AML Package sets the structural direction for how beneficial-ownership data is held and supervised: the package rests on three distinct instruments, the directly-applicable AML Regulation carrying the single rulebook of due-diligence and ownership-transparency content, the sixth AML Directive transposed state by state covering institutional and registry-access arrangements, and a separate Regulation establishing a new EU-level Anti-Money Laundering Authority with direct and indirect supervisory reach over certain obliged entities and, in time, an evolving role in registry oversight. That architecture is durable structural backdrop rather than a single-cycle development, and it is the frame against which this cycles Liechtenstein-specific signal should be read, even though Liechtenstein, as a European Economic Area state rather than an EU member state, interacts with it on an incorporation lag through the EEA Agreement rather than as a direct EU addressee. Continue reading The directly relevant development for Liechtenstein this cycle is not that backdrop but an operational failure at the national level: the Register of Beneficial Owners, the VwbP, was breached overnight on 29-30 July 2026, with an unknown actor gaining unauthorised digital access and exfiltrating ownership data on approximately 31,000 legal entities, spanning companies, foundations and trusts. The government has been explicit that there is no evidence the data itself was altered or deleted, and that the banking sector was not touched by the intrusion, but the exfiltration of data at that scale from the single registry meant to hold ownership information on behalf of the state is a material event regardless of whether integrity was preserved, because the confidentiality of that data, not merely its accuracy, is itself a component of the transparency regimes credibility. This lands with particular weight given Liechtensteins own evaluation history. The Council of Europes MONEYVAL mechanism, in its 2022 mutual evaluation, placed Liechtenstein on the regular, non-enhanced follow-up track, a result achieved by only five of the jurisdictions evaluated in that round, with no onsite re-evaluation due until 2030. That same evaluation nonetheless identified beneficial-ownership transparency as one of the specific areas where further improvement was needed, alongside supervision and private-sector application of preventative measures. A breach of the central ownership register, arriving years into that follow-up period, speaks directly to the identified area of concern rather than to an unrelated or newly discovered weakness, and it will likely be read by evaluators and counterparties alike as evidence of whether the identified gap has in fact been closed or merely relocated from a paper-based to a digital vulnerability. The other side of the ledger is Liechtensteins separate push to modernise its anti-money-laundering legal architecture more broadly. The government adopted a consultation report on 3 March 2026 for a new national Anti-Money Laundering Act, which would transpose the sixth EU Directive and repeal the existing Due Diligence Act, while the directly-applicable EU AML Regulation is expected to take over the substantive due-diligence content once incorporated into the EEA Agreement. A working target date of 10 July 2027 has been floated for both instruments, though that specific date rests on secondary commentary rather than a primary governmental confirmation, and formal incorporation into the EEA framework has not yet been confirmed. This legislative modernisation effort will, in time, carry forward whatever lessons are drawn from the registry breach, but the breach itself sits squarely within the existing legal and technical architecture, not the prospective one. #### Outlook The near-term question is less about Liechtensteins legislative direction, which is well understood and broadly aligned with the European Economic Area trajectory, than about the operational resilience of the registry infrastructure that sits underneath it. Whether the response to the breach, in terms of technical remediation and any disclosed governance changes, is judged adequate will shape how the beneficial-ownership transparency finding from the 2022 MONEYVAL evaluation is read heading toward the next onsite assessment around 2030. On the legislative track, the national Anti-Money Laundering Act and the EU Regulations incorporation remain, as scheduled, targeted for 10 July 2027, but that date is not yet confirmed against a primary source and remains contingent on a European Economic Area Joint Committee incorporation decision that has not yet been finalised for Liechtenstein. Until incorporation occurs, the existing Due Diligence Act continues to govern obliged entities, meaning the registry that was breached remains, for now, the same instrument that will eventually sit inside the new architecture rather than a predecessor system being phased out independently of it. #### Enabler Jurisdictions and Professional Facilitators The professional-facilitator exposure of Liechtenstein is concentrated, structurally, in a single sector: trust and company service providers administering the jurisdiction foundation and Anstalt vehicles. The 2022 MONEYVAL Mutual Evaluation Report concluded that it was not possible to determine that effective, proportionate or dissuasive sanctions have been applied by the Financial Market Authority, and identified enforcement against the TCSP sector specifically as inadequate. That finding is not abstract: it is the persistent, systemically significant deficiency underlying two independent exposures documented this cycle. In the Potanin case, TCSP-administered foundation structures with minor-child sole beneficiaries were used to preserve continuing economic control by a sanctioned oligarch after a nominal ownership transfer. In a second and unrelated case, the Liechtenstein Office of the Public Prosecutor opened preliminary investigations against a natural person and a legal entity following the multi-billion-euro insolvency of the Signa group founded by Austrian property magnate Rene Benko, involving Liechtenstein legal structures; Benko was found guilty in Austria in December 2025 of related fraud offences. That two independently sourced cases, one sanctions-driven and one insolvency-fraud-driven, both implicate the same TCSP gatekeeping weakness is the strongest evidence available this cycle that the deficiency is structural rather than incidental to either case. Continue reading The formal jurisdictional classification of Liechtenstein does not currently reflect this concentrated exposure. It remains absent from both the FATF grey and black lists as of the June 2026 plenary and is monitored instead through the MONEYVAL standard post-MER follow-up process rather than the FATF ICRG track, meaning the jurisdiction faces no external pressure mechanism beyond the MONEYVAL own review cadence to remediate the TCSP enforcement gap identified in 2022. This is itself an analytically significant absence: a formally clean list status persists alongside two independently documented instances of the exact sectoral weakness the 2022 MER flagged, and no material 2025-2026 FMA enforcement-action data has been identified in open sources sufficient to verify whether the deficiency is closing. The jurisdiction risk tracker classifies the overall enforcement-versus-enablement posture of Liechtenstein as mixed and its exposure as structural rather than episodic, a classification borne out by the TCSP finding: the deficiency is not a single supervisory lapse but a documented, MER-sourced weakness that two unrelated schemes, distinct in origin, both independently exploited. The professional-services ecosystem of Liechtenstein, oriented toward high-net-worth wealth structuring through foundations and Anstalten, is precisely the kind of enabler infrastructure that generates limited enforcement volume relative to larger financial centres while carrying disproportionate exposure when the underlying vehicles are misused, a pattern the architecture-over-incident framing is designed to surface. The evidentiary basis for judging remediation progress is itself limited: publicly available Tier 2 and Tier 3 reporting on individual 2025-2026 FMA enforcement actions is sparse relative to larger financial centres, forcing disproportionate reliance on the 2022 MER and on foreign press and regulatory sourcing, a gap in the Sentinel own intelligence coverage rather than a statement about the underlying enforcement activity of Liechtenstein. #### Outlook A MONEYVAL follow-up review of the 2022 MER priority actions, with a specific focus on TCSP enforcement remediation, is expected within the next six to eighteen months and is the most direct near-term test of whether the enabler-jurisdiction profile of Liechtenstein is improving. Given that two structurally similar TCSP exposures have now surfaced independently since the MER, from a sanctioned-oligarch concealment case and a separate insolvency-fraud probe, continued reliance on the foundation and Anstalt sector of Liechtenstein by parties seeking to obscure beneficial control or shield assets from cross-border creditors and prosecutors should be regarded as a standing rather than a resolved risk pending documented FMA enforcement improvement. #### Conflict Finance and Extractive-Industry Integrity No material Liechtenstein-specific conflict-finance or extractive-industry development was identified this cycle. Liechtenstein is not documented as a physical transit corridor for conflict commodities, nor does this cycle research surface any Liechtenstein-domiciled entity, scheme or enforcement action tied to financing armed conflict or extractive-sector corruption. This is consistent with the overall risk profile of Liechtenstein as a wealth-structuring and fiduciary-services centre rather than a commodity-trading or extraction jurisdiction: its structural exposure, evidenced elsewhere this cycle in the foundation and TCSP sector, runs through beneficial-ownership concealment and sanctions-evasion typologies rather than physical commodity flows. Continue reading The absence of a D4 finding should be read as an honest gap rather than an assurance of clean status; Liechtenstein-domiciled foundations and Anstalten are, in principle, capable of holding equity or debt interests in extractive ventures or conflict-adjacent entities elsewhere, and this cycle baseline research did not surface evidence of, or specifically rule out, such holdings. The gap reflects the scope and sourcing available this cycle rather than a considered negative finding. This absence of an enforcement-visible D4 finding is not itself an enablement signal in the way that non-enforcement in a permissive jurisdiction can be for other domains, since the structural profile of Liechtenstein does not position it as a natural node for conflict-commodity financing in the first instance. #### Outlook Given the demonstrated role of Liechtenstein as a wealth-structuring rather than commodity-transit jurisdiction, conflict-finance signal is more likely to surface, if it exists, through the foundation and Anstalt ownership-concealment channel already documented in the sanctions and beneficial-ownership domains than through a distinct extractive-industry vector. Future cycles should specifically probe whether any Liechtenstein-domiciled vehicle holds interests in conflict-affected extractive assets before this domain can be assessed with confidence rather than flagged as quiet. #### Crypto, Digital Assets, and Financial Innovation The own digital-asset regulatory architecture of Liechtenstein is the direct subject of this cycle D5 signal. The bespoke 2020 token-container law of the jurisdiction, the Blockchain Act (TVTG), which regulates virtual-asset service providers and token issuers under the Financial Market Authority and the Office for Financial Market Innovation and Digitalisation, is under active revision to prepare for equivalence with the EU Markets in Crypto-Assets Regulation. Liechtenstein built the TVTG as a national framework years before MiCA existed, and it now faces a structural choice common to non-EU EEA states: because MiCA does not apply directly to Liechtenstein, alignment can only occur through domestic legislative revision of the existing token-container model rather than automatic adoption of the EU regime. That revision is described as ongoing rather than finalised, and the precise text of the revised TVTG has not been identified in this cycle sourcing, limiting assessment of exactly how the interim supervisory-divergence window will be closed. Continue reading That interim window is the operative risk for Liechtenstein-licensed crypto-asset operators and their counterparties: token-economy entities can continue to operate under the TVTG national authorisation regime rather than the MiCA CASP authorisation and Travel Rule framework until Liechtenstein own alignment legislation is finalised and, where relevant, until MiCA is incorporated into the EEA obligations of Liechtenstein. This is the same jurisdiction-shopping risk pattern flagged elsewhere in Europe: a national licensing regime that has not yet been harmonised with the MiCA authorisation and Travel Rule standard can, in principle, be more attractive to counterparties seeking a lighter or differently calibrated compliance burden than an equivalent MiCA-licensed EU entity, even where no bad-faith intent exists on the part of the Liechtenstein regulator. Globally, MiCA and the broader FATF virtual-asset standards set the direction of travel for crypto-asset regulation, and the TVTG revision of Liechtenstein is best read as a jurisdiction converging toward that global direction from a bespoke starting point rather than an EU member state directly transposing a directive. The absence of a confirmed finalisation date for the revised TVTG, or of a confirmed MiCA-incorporation timeline given the non-EU EEA status of Liechtenstein, means the duration of the interim divergence window is not currently quantifiable with confidence. This domestic crypto story sits alongside the broader financial-architecture profile of Liechtenstein as a small, well-regulated wealth-structuring centre; there is no evidence this cycle of a Liechtenstein-specific crypto-sanctions-evasion or DeFi-enforcement case comparable to the Potanin foundation matter, and the TVTG revision itself is a supervisory-modernisation development rather than an enforcement action. Read through the architecture-over-incident lens, this is precisely the moment at which a jurisdiction crypto framework is most instructive: before any incident forces attention, a decision about how quickly and how completely to align a bespoke digital-asset regime with an emerging international standard is the structural variable that will determine how exploitable that regime is for however long the interim period lasts. There is a plausible, though not yet evidenced, connection between the FIU.net integration of Liechtenstein and its digital-asset supervisory posture: real-time cross-border STR matching capability could, in principle, extend the practical detection capacity of the jurisdiction for crypto-linked suspicious activity ahead of formal TVTG-MiCA alignment, though this cycle sourcing does not confirm any such operational linkage and it should not be assumed absent direct evidence. The obligation landscape for Liechtenstein-licensed crypto-asset operators therefore currently rests on the TVTG rather than on the MiCA CASP authorisation and Travel Rule regime, a distinction firms and their counterparties should track explicitly rather than assume converges automatically with the rest of the EEA crypto framework. #### Outlook The TVTG revision is the single most consequential near-term regulatory-horizon item for the crypto and digital-asset sector of Liechtenstein, expected to progress toward MiCA alignment on a horizon currently assessed around 2027, though this estimate carries a wide, multi-year uncertainty band given the absence of a finalised text. Crypto-asset operators and their counterparties should treat current TVTG-based authorisation in Liechtenstein as a national regime operating in parallel with, rather than as an equivalent substitute for, MiCA authorisation until the revision is finalised and any necessary EEA incorporation step is complete. #### Compliance Technology and Active Defence The most concrete compliance-technology development for Liechtenstein this cycle is the connection of its Financial Intelligence Unit, on 3 February 2025, to the AMLA-managed Next-Generation FIU.net system. That connection gave Liechtenstein real-time cross-matching, dissemination and pseudonymous hit-and-no-hit capability with EU FIUs, Norway, Iceland and Europol, under a legal avenue created by the EU AML reform package, notwithstanding the status of Liechtenstein as a non-EU EEA state outside the direct legal perimeter of that package. Read as SupTech and RegTech infrastructure rather than as a policy announcement, the FIU.net connection is a functional capability upgrade that materially outpaces the formal legal question of whether and when the AML Regulation, sixth AML Directive and AMLA Regulation are incorporated into Liechtenstein law via the EEA Joint Committee mechanism. This is the clearest instance this cycle of active-defence infrastructure running ahead of supervisory harmonisation: Liechtenstein now shares financial intelligence within the AMLA ecosystem on close to the same technical footing as an EU member state, while remaining formally outside the 2028 AMLA direct-supervision perimeter absent its own incorporation decision. Continue reading This functional-ahead-of-formal pattern has implications beyond FIU.net itself. It suggests that the authorities of Liechtenstein and the AMLA-adjacent institutional architecture are capable of extending operational, technology-mediated cooperation to non-EU EEA states pragmatically, even where the underlying legal instruments have not yet been extended to those states, a pattern with cross-monitor relevance for how other non-EU EEA and EFTA jurisdictions may be brought into EU-adjacent compliance-technology infrastructure ahead of full legal harmonisation. At the same time, the own compliance-technology and enforcement-transparency profile of Liechtenstein is constrained by an evidence-availability gap in the intelligence corpus itself: publicly available Tier 2 and Tier 3 reporting on individual FMA enforcement actions specific to 2025-2026 is sparse relative to larger financial centres, forcing disproportionate reliance on the 2022 MONEYVAL Mutual Evaluation Report and on foreign OFAC and press sourcing to assess whether the TCSP enforcement weaknesses that report identified are being remediated through improved supervisory technology or otherwise. This is a gap in the Sentinel own intelligence coverage rather than a statement about the underlying compliance-technology posture of Liechtenstein, but it means confidence in any positive trajectory read on the active-defence capability of Liechtenstein should currently be treated as assessed rather than high. It is worth stating explicitly that a real-time information-sharing capability and an effective sanctioning regime are distinct capacities: FIU.net connectivity improves the ability of Liechtenstein to detect and disseminate suspicious-activity intelligence across borders, but it does not by itself remedy the enforcement-action weakness MONEYVAL identified specifically in the TCSP sector, since detection and sanctioning sit at different points in the supervisory chain. The Potanin and Signa cases both originated from detection or disclosure mechanisms outside the domestic enforcement apparatus of Liechtenstein, OFAC casework in one instance and an Austrian criminal proceeding in the other, which is itself informative about where the compliance-technology strengths and enforcement-capacity weaknesses of Liechtenstein currently sit relative to each other. The crypto-sector supervisory technology of Liechtenstein, administered through the Financial Market Authority and the Office for Financial Market Innovation and Digitalisation under the Blockchain Act framework, is a second compliance-technology dimension worth monitoring alongside FIU.net, since the ongoing TVTG revision toward MiCA equivalence will itself require corresponding supervisory-technology build-out if Liechtenstein intends to match MiCA CASP-level monitoring expectations rather than simply its licensing text. #### Outlook The FIU.net connection is likely to remain the single clearest concrete compliance-technology data point for Liechtenstein through at least the 2026-2027 window, given that the AMLA work programme and supervisory-methodology build-out expected in the second half of 2026 is an EU-internal development Liechtenstein sits outside pending its own EEA incorporation decision. Whether the functional-ahead-of-formal pattern of Liechtenstein translates into demonstrable TCSP-enforcement improvement, the domain in which MONEYVAL identified the most significant weakness of the jurisdiction, remains the more consequential open question, and the upcoming MONEYVAL follow-up review is the most direct near-term test of that translation. #### AML/CTF Regime Liechtensteins anti-money-laundering and counter-terrorist-financing regime is in the early stages of a structural transition. The government adopted a consultation report on 3 March 2026 for a new national Anti-Money Laundering Act, intended to transpose the sixth EU Anti-Money Laundering Directive and to repeal the existing Due Diligence Act (the SPG), which has governed customer due diligence domestically for years. Running alongside that national transposition process is the directly-applicable EU AML Regulation, which, once incorporated into the EEA Agreement, will take over the substantive due-diligence content currently held in the SPG, while the new national Act absorbs the institutional and supervisory-cooperation provisions transposed from the Directive. A working target date of 10 July 2027 has been cited in secondary commentary for both the Regulations direct application and the Acts entry into force, though that specific date has not been independently confirmed against a primary government source this cycle, and formal incorporation into the EEA framework remains pending. Continue reading This three-instrument architecture, a directly-applicable Regulation, a transposed Directive, and a separate Regulation establishing a new EU-level Anti-Money Laundering Authority with direct and indirect supervisory reach, represents a durable shift away from a purely national-text, nationally-supervised model toward a hybrid regime with an EU-level supervisory layer above national authorities. For a European Economic Area state such as Liechtenstein, participation flows through incorporation into the EEA Agreement rather than direct EU membership, which is why the timing of domestic implementation lags the EU-internal rollout and remains contingent on a Joint Committee decision rather than resting entirely in the governments own hands. Against that backdrop of legislative modernisation, Liechtensteins existing regime continues to show an active enforcement posture. The Financial Market Authoritys most recent annual report recorded CHF 590,000 in fines that became legally binding across 17 separate proceedings, the majority, 13 of the 17, for violations of the Due Diligence Act specifically. That level of enforcement activity indicates a supervisory function that continues to apply the current legal framework with some consistency even as the framework itself is scheduled for replacement, rather than one that has begun to stand down ahead of the transition. The regimes external standing also remains a relevant data point. The Council of Europes MONEYVAL mechanism placed Liechtenstein on its regular, non-enhanced follow-up track following the 2022 mutual evaluation, a result shared with only four other evaluated jurisdictions, and no onsite reassessment is due until 2030. That evaluation did identify supervision, private-sector application of preventative measures, and beneficial-ownership transparency as areas needing further improvement, which gives the current cycles beneficial-ownership register breach a degree of relevance to the AML/CTF regimes broader credibility, even though the breach itself is a data-security event rather than a finding about due-diligence practice as such. #### Outlook The principal uncertainty for Liechtensteins AML/CTF trajectory is timing rather than direction: the national Anti-Money Laundering Act and the directly-applicable EU Regulation are, as scheduled, working toward a target date of 10 July 2027, but that date rests on commentary rather than a confirmed primary source, and the underlying EEA Joint Committee incorporation decision for Liechtenstein has not yet been confirmed. Until incorporation occurs, obliged entities continue to operate under the existing Due Diligence Act, and the Financial Market Authority continues to enforce against it, as the CHF 590,000 in recent fines illustrates. The next MONEYVAL onsite evaluation, not due until 2030, gives Liechtenstein a multi-year window in which to demonstrate that the legislative transition, once it occurs, has addressed the supervision and transparency gaps identified in 2022, rather than simply recreating them under new instrument names. #### Commercial Activity Liechtenstein's FMA was active on two fronts this cycle that, together, illustrate both the growth and the policing sides of the jurisdiction's financial-services sector. On the growth side, three Swiss-linked crypto firms -- RuleMatch Europe AG, Bitcoin Suisse (Europe) AG and Sygnum Europe AG -- completed MiCA Crypto-Asset Service Provider authorisation through Vaduz subsidiaries in June 2026, coinciding with the scheduled expiry of transitional TVTG registrations for MiCAR-scoped activities. This represents a concrete, dated commercial pattern of market entry rather than a structural regulatory change, and it reflects sustained demand among Swiss-domiciled digital-asset firms for Liechtenstein-based EEA market access. Continue reading On the enforcement side, the FMA continued supervisory action against TGI AG, ordering the firm to cease distribution of gold-purchase-linked products and to stop taking deposits without the required authorisation. An Appeals Commission ruling in August 2026 partially upheld relief sought by TGI AG regarding the suspensive effect of the FMA's order, indicating the matter remains contested rather than fully resolved. This is conventional supervisory enforcement against unauthorised deposit-taking activity, distinct in kind from the licensing-wave commercial activity described above, but evidence that the FMA continues to act against unlicensed conduct even as its authorisation workload from the MiCA transition has grown materially. Taken together, these two threads show a regulator managing simultaneous growth in licensed activity and active policing of unlicensed activity, within the same supervisory period. Neither thread reflects a change to Liechtenstein's underlying legal framework; both are commercial and enforcement developments occurring within a stable regulatory architecture. #### Outlook The TGI AG matter remains live following the partial Appeals Commission ruling, and its eventual resolution will be a useful marker of how Liechtenstein's enforcement processes handle contested suspensive-effect questions. On the licensing side, whether the pace of MiCA CASP authorisations seen this cycle continues into subsequent periods will indicate whether Liechtenstein's gateway function for Swiss-linked digital-asset firms is a sustained structural feature or a transition-driven clustering effect tied to the TVTG bridge closure. Regulatory horizon Consultation 10 Jul 2027 · ±year ### National AMLA (replacing SPG), AMLR direct application — EEA incorporation pending Substantive due-diligence rules move from the national SPG into the directly-applicable EU AMLR; institutional/supervisory-cooperation rules move into the new national AMLA transposing AMLD6. [Source](https://www.regierung.li/medienportal-medium/16182/234285/0/medienmitteilung) Adopted 2027-Q3 · ±quarter ### EU Anti-Money Laundering Regulation (AMLR) direct application Replaces SPG as the directly applicable substantive due-diligence instrument for obliged entities in Liechtenstein from 10 July 2027. [European Union, via EEA incorporation Source](https://www.grantthornton.ch/en/insights/eu-aml-package/) 2 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### The national beneficial-ownership register was breached, exposing data on roughly 31,000 entities, while enforcement against Due Diligence Act breaches continued at CHF 590,000 across 17 proceedings. The breach of the ownership register does not itself appear to require a suspicious-activity filing on current evidence, since the government reports no alteration of the underlying data, but it raises the profile of any counterparty whose ownership data was exposed and may be exploited downstream. The sustained Due Diligence Act enforcement volume signals an active supervisory posture under the current legal framework. 3 evidence refs Compliance ### A new national Anti-Money Laundering Act is in consultation, targeting a working date of 10 July 2027 to replace the Due Diligence Act alongside direct application of the EU AML Regulation. Obliged entities should expect their domestic due-diligence text to migrate from the national Due Diligence Act into a directly-applicable EU Regulation, with institutional provisions carried separately in the new national Act, though the timing remains contingent on a European Economic Area incorporation decision not yet confirmed. 1 evidence refs Legal ### No material change for legal counsel this cycle beyond the pending AML Act consultation and register breach already captured elsewhere. No material change for this persona this cycle Board ### A cyberattack on the national beneficial-ownership register exposed data on approximately 31,000 entities, testing confidence in a transparency instrument MONEYVAL had already flagged as needing improvement. This is a reputational and institutional-credibility matter that intersects with the countrys most recent international evaluation, which specifically identified beneficial-ownership transparency as an area needing improvement; the next onsite evaluation is not due until 2030, giving time to demonstrate remediation. 3 evidence refs CTO ### The national beneficial-ownership registers infrastructure was compromised overnight, with data on roughly 31,000 entities exfiltrated. A centralised government registry holding sensitive ownership data was subject to unauthorised access; this is a direct data-security event relevant to any technical architecture built around reliance on, or interface with, that registry. 2 evidence refs Risk ### The beneficial-ownership register breach is an episodic cyber-risk event against an otherwise stable AML/CTF baseline that MONEYVAL rated favourably in 2022. The breach increases operational and reputational risk in the near term without, on current evidence, indicating a change in the underlying regulatory or enforcement posture, which remains on the favourable regular follow-up track with no reassessment due until 2030. 3 evidence refs Operations ### No material change for this persona this cycle. No material change for this persona this cycle Audit ### The Financial Market Authority recorded CHF 590,000 in fines across 17 proceedings in its latest annual report, 13 of which concerned Due Diligence Act violations. This gives a documented, quantified basis for assessing whether current controls are generating enforceable findings consistent with the existing Due Diligence Act, ahead of its planned replacement under the pending national AML Act. 1 evidence refs Scenario sketches ### Illustrative scenario: AMLA supervisory transition reshaping cross-border obliged-entity oversight Illustrative scenario for analytical orientation only. As the EU AML Package moves from a purely national supervisory model toward one with a direct and indirect EU-level supervisory layer under the new Anti-Money Laundering Authority, a European Economic Area state such as Liechtenstein could see a portion of its cross-border obliged entities, those operating across multiple Economic Area states, drawn into a hybrid oversight arrangement that sits above the Financial Market Authoritys purely domestic remit. This could, in principle, alter where an entity seeking regulatory arbitrage would look first, shifting attention from gaps between purely national supervisory regimes toward gaps in how the new EU-level authority coordinates with non-EU European Economic Area supervisors during the incorporation period. This is illustration of a possible structural mechanism, not an observed fact or a prediction. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No LI-specific Russian sanctions-evasion signal located this cycle. T2 · EU AML Package / AMLA watch AMLR/6AMLD/AMLA three-instrument status; consultation report adopted 3 March 2026; working target date 10 July 2027. T3 · FATF Grey List no_change Liechtenstein is not on the FATF grey list; MONEYVAL 2022 placed it on regular follow-up track. T4 · Beneficial-Ownership Register Status material_change VwbP register breached 29-30 July 2026; ~31,000 entities' data exfiltrated. T5 · Crypto / VASP Regulatory Framework stable LI CASP count held steady at 12 across October 2026 ESMA snapshots; TVTG-to-MiCA transition closure on 1 July 2026 is the structural event inherited into this window. T6 · Sanctions Regime Divergence no_change No LI-specific EU/US/UK sanctions divergence event found this cycle. Registers ### Enforcement actions - 31 Mar 2026 - 3 Feb 2025 - 15 Jul 2025 - 4 Dec 2025 - 26 May 2026 - 8 Oct 2026 - 4 Oct 2026 - 1 Jan 2026 - OFAC issued a sanctions advisory on sham transactions, explicitly using the June 2024 designation of four Liechtenstein foundations (holding assets nominally transferred by a sanctioned Russian oligarch to minor-child beneficiaries) as a worked example of concealed continuing beneficial interest, reinforcing enforcement expectations for foreign fiduciaries dealing with Liechtenstein-domiciled vehicles. 31 Mar 2026 - Liechtenstein's FIU (together with Iceland's) was connected to the 'Next-Generation' FIU.net system on 3 February 2025, expanding cross-border STR reporting, dissemination and pseudonymous hit/no-hit matching to a non-EU EEA state under new legal avenues created by the EU's AML/CFT reform package. 3 Feb 2025 - Liechtenstein formally aligned its national sanctions ordinance with EU Council Decision (CFSP) 2025/1425, which added five natural persons to the EU Russia-related restrictive-measures list, committing to ensure national policy conforms notwithstanding Liechtenstein's non-EU EEA/EFTA status. 15 Jul 2025 - Liechtenstein aligned with the Council's extension of restrictive measures on serious human-rights violations and abuses (Decision (CFSP) 2025/2469 of 4 December 2025), which updated entries for 27 individuals and 12 entities and extended the regime until December 2026. 4 Dec 2025 ### Sanctions changes - 23 Oct 2025 - 26 May 2025 - 4 Dec 2025 - 12 Jun 2024 - Liechtenstein, as an EEA/EFTA state, holds no Council vote on EU sanctions decisions but has repeatedly aligned its national ordinance with successive 2025 EU Russia sanctions packages (May, July, Aug, Sept, Oct, Nov, Dec 2025), including the 19th package targeting energy, third-country banks and crypto providers (23 Oct 2025). 23 Oct 2025 - Liechtenstein aligned with the Council's one-year prolongation (Decision (CFSP) 2025/1070, 26 May 2025) of individual restrictive measures targeting those undermining Ukraine's territorial integrity, extending the regime to 28 May 2026. 26 May 2025 - The European Commission's most recent updates to the EU high-risk third-country AML list (Delegated Regulations (EU) 2026/46 and 2026/83, adopting Russia and removing/adding several other jurisdictions) confirm Liechtenstein's continued absence from the EU AML high-risk third-country list throughout the review window. 4 Dec 2025 ### Regulatory horizon (register) - AMLD6 beneficial-ownership register & AMLA technical-standards transposition - AMLD6 beneficial-ownership register & AMLA technical-standards transposition - EU AML Regulation (AMLR) / AMLD6 application and national AMLA bridge - Liechtenstein Anti-Money Laundering Act (AMLA) - national 6AMLD transposition - EU Anti-Money Laundering Regulation (AMLR) direct application - National AMLA (replacing SPG), AMLR direct application — EEA incorporation pending - Blockchain Act (TVTG) revision for MiCA alignment - EEA incorporation of EU AML Package (AMLR/6AMLD/AMLA) into Liechtenstein law - MONEYVAL follow-up review of Liechtenstein's 2022 MER priority actions ### Active schemes - [HIGH] Oligarch beneficial-ownership concealment via Liechtenstein foundations - [HIGH] TCSP/foundation structuring exposure in Signa insolvency collapse - Blockchain Act (TVTG) framework in transition toward MiCA Sources - [OFAC Information for Industry Groups | Office of Foreign Assets Control](https://ofac.treasury.gov/additional-ofac-resources/ofac-information-for-industry-groups) - [https://www.techtimes.com/articles/322751/20260803/liechtenstein-data-breach-attackers-hack-aml-registry-exposing-eu-security-flaw.htm](https://www.techtimes.com/articles/322751/20260803/liechtenstein-data-breach-attackers-hack-aml-registry-exposing-eu-security-flaw.htm) - [https://www.bloomberg.com/news/features/2026-08-14/liechtenstein-rules-out-paying-hackers-ransom-after-data-breach](https://www.bloomberg.com/news/features/2026-08-14/liechtenstein-rules-out-paying-hackers-ransom-after-data-breach) - [https://www.grantthornton.ch/en/insights/eu-aml-package/](https://www.grantthornton.ch/en/insights/eu-aml-package/) - [https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/liechtenstein](https://practiceguides.chambers.com/practice-guides/banking-regulation-2026/liechtenstein) - [https://www.coe.int/en/web/human-rights-rule-of-law/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism](https://www.coe.int/en/web/human-rights-rule-of-law/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism) - [https://mlroconsulting.com/aml-requirements/aml-requirements-liechtenstein/](https://mlroconsulting.com/aml-requirements/aml-requirements-liechtenstein/) - [https://www.legal500.com/developments/thought-leadership/micar-transition-watch-why-liechtensteins-tvtg-vasps-should-prepare-for-an-30-june-2026-cut-off-and-what-to-do-now/](https://www.legal500.com/developments/thought-leadership/micar-transition-watch-why-liechtensteins-tvtg-vasps-should-prepare-for-an-30-june-2026-cut-off-and-what-to-do-now/) - [https://www.fma-li.li/en/supervision-regulation/fintech/micar](https://www.fma-li.li/en/supervision-regulation/fintech/micar) - [https://www.fma-li.li/en/supervision-regulation/anti-money-laundering](https://www.fma-li.li/en/supervision-regulation/anti-money-laundering) - [https://www.regierung.li/medienportal-medium/16444/231503/0/medienmitteilung](https://www.regierung.li/medienportal-medium/16444/231503/0/medienmitteilung) - [https://eucrim.eu/news/moneyval-fifth-round-evaluation-report-on-liechtenstein/](https://eucrim.eu/news/moneyval-fifth-round-evaluation-report-on-liechtenstein/) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-liechtenstein-2022.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-liechtenstein-2022.html) - [https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/](https://zavia.ai/eu-beneficial-ownership-in-2026-amlr-amld6-amla-explained/) - [Financial Intelligence Unit (FIU) Liechtenstein](https://www.llv.li/en/national-administration/financial-intelligence-unit/useful-information/international-affairs-and-sanctions) - [Universität Liechtenstein](https://www.uni.li/de/blog/2025/12/internationale-sanktionen-als-pruefstein) - [United24 Media](https://united24media.com/latest-news/us-sanctions-turn-liechtenstein-into-a-graveyard-of-russian-wealth-vehicles-9669) - [Council of Europe (MONEYVAL)](https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism) - [Finanzmarktaufsicht (FMA) Liechtenstein](https://www.fma-li.li/en/supervision-regulation/anti-money-laundering) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Liechtenstein.html) - [SiGMA](https://sigma.world/news/cambodia-anti-gambling-drive-fatf-grey-list/) - [Finanzmarktaufsicht (FMA) Liechtenstein](https://www.fma-li.li/en/supervision-regulation/fintech/micar) - [https://www.twobirds.com/en/insights/2026/eu-list-of-highrisk-countries-and-jurisdictions-for-money-laundering-and-terrorism-financing-amended](https://www.twobirds.com/en/insights/2026/eu-list-of-highrisk-countries-and-jurisdictions-for-money-laundering-and-terrorism-financing-amended) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofliechtenstein.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofliechtenstein.html) - [https://www.regierung.li/medienportal-medium/16444/234654/0/medienmitteilung](https://www.regierung.li/medienportal-medium/16444/234654/0/medienmitteilung) - [https://www.regierung.li/medienportal-medium/16444/234948/0/medienmitteilung](https://www.regierung.li/medienportal-medium/16444/234948/0/medienmitteilung) - [https://www.regierung.li/thema/17106/cyberattack-on-the-vwbp-latest-information?id=234669](https://www.regierung.li/thema/17106/cyberattack-on-the-vwbp-latest-information?id=234669) - [https://www.fatf-gafi.org/en/countries/j-m/liechtenstein/documents/mutualevaluationofliechtenstein.html](https://www.fatf-gafi.org/en/countries/j-m/liechtenstein/documents/mutualevaluationofliechtenstein.html) - [https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism](https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism) - [https://cryptovalleyjournal.com/focus/legal-and-compliance/swiss-crypto-service-providers-secure-mica-authorization/](https://cryptovalleyjournal.com/focus/legal-and-compliance/swiss-crypto-service-providers-secure-mica-authorization/) - [https://www.fma-li.li/en/news/announcement-fma-imposes-measures-against-tgi-ag-for-unauthorized-operation-of-the-deposit-business-1629](https://www.fma-li.li/en/news/announcement-fma-imposes-measures-against-tgi-ag-for-unauthorized-operation-of-the-deposit-business-1629) - [https://www.imf.org/en/news/articles/2025/01/20/concluding-statement-25-liechtenstein](https://www.imf.org/en/news/articles/2025/01/20/concluding-statement-25-liechtenstein) - [https://www.fma-li.li/en](https://www.fma-li.li/en) - [https://verbraucherschutzforum.berlin/2026-10-08/fma-liechtenstein-warnt-vor-klonfirma-financial-partner-ltd-com-identitaetsmissbrauch-zulasten-der-financial-partners-fp-ltd-aus-vaduz-439394/](https://verbraucherschutzforum.berlin/2026-10-08/fma-liechtenstein-warnt-vor-klonfirma-financial-partner-ltd-com-identitaetsmissbrauch-zulasten-der-financial-partners-fp-ltd-aus-vaduz-439394/) - [https://www.coe.int/en/web/moneyval/assessment-calendar](https://www.coe.int/en/web/moneyval/assessment-calendar) - [https://www.diebewertung.de/tgi-ag-neue-massnahmen-der-fma-liechtenstein/](https://www.diebewertung.de/tgi-ag-neue-massnahmen-der-fma-liechtenstein/) - [https://www.fma-li.li/en/news/fma-guidance-2026-1-issued-1609](https://www.fma-li.li/en/news/fma-guidance-2026-1-issued-1609) - [Euronews](https://www.euronews.com/2026/08/03/cyberattack-hits-liechtensteins-anti-money-laundering-data-register-vaduz-says) - [AML Intelligence](https://www.amlintelligence.com/2026/08/news-hackers-breach-liechtenstein-beneficial-ownership-register-access-data-on-31000-entities/) - [Regierung des Fürstentums Liechtenstein](https://www.regierung.li/medienportal-medium/16182/234285/0/medienmitteilung) - [Council of Europe / MONEYVAL](https://www.coe.int/en/web/moneyval/-/moneyval-acknowledges-liechtenstein-s-progress-in-improving-measures-to-combat-money-laundering-and-financing-of-terrorism) - [CryptoSlate](https://cryptoslate.com/crypto-laws/liechtenstein-token-tt-service-provider-act-tvtg/) - [Financial Market Authority Liechtenstein](https://www.fma-li.li/en/news/fma-publishes-annual-report-2025-1605) - [Liechtenstein's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-liechtenstein-2022.html) - [MONEYVAL-Mutual-Evaluation-Liechtenstein-2022. ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MONEYVAL-Mutual-Evaluation-Liechtenstein-2022.pdf.coredownload.inline.pdf) - [Mutual Evaluation of Liechtenstein](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofliechtenstein.html) - [1 Fifth Round Mutual Evaluation Report April 2021](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MONEYVAL-Mutual-Evaluation-Liechtenstein-2022.pdf) - [Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL)](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [FATF](https://www.fatf-gafi.org/en/home.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Hungary's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-hungary-2016.html) - [Liechtenstein](https://www.fatf-gafi.org/en/countries/detail/Liechtenstein.html) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of the situation in Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/high-representative-statement-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [Commission to discuss with Member States and international partners the implementation of sanctions against Russia and Belarus - European Commission](https://finance.ec.europa.eu/news/commission-discuss-member-states-and-international-partners-implementation-sanctions-against-russia-2025-04-07_en) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/08/11/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-actions-destabilising-the-situation-in-ukraine/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Russia-related Designations; Publication of Russia-related Determination; Issuance of Russia-related General Licenses and Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240612) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Russia-related Designations; Issuance of Russia-related General Licenses and new and amended Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240223) - [Questions and Answers on the 14th package of restrictive measures against Russia](https://ec.europa.eu/commission/presscorner/detail/es/qanda_24_3425) - [Issuance of Amended Russia-related Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20251218_33) - ['Next-Generation' FIU.net - Finance - European Commission](https://finance.ec.europa.eu/news/next-generation-fiunet-2025-02-04_en) - [Suspicious Activity Reports April 2024 - March 2025 ANNUAL REPORT SARs](https://www.nationalcrimeagency.gov.uk/who-we-are/publications/786-sars-annual-report-2025/file) - [1 United States Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/advisory/advis19.pdf) - [SAR Activity Review](https://www.fincen.gov/system/files/shared/sar_tti_02.pdf) - [Country Review Report of Liechtenstein](https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/Liechtenstein_Final_Report.pdf) - [FIU.net - European Commission](https://ec.europa.eu/transparency/expert-groups-register/screen/index.cfm?do=groupDetail.groupDetail&groupID=3251) - [1 EU Blockchain Ecosystem Developments 2024 EU Blockchain Ecosystem](https://blockchain-observatory.ec.europa.eu/document/download/fd34e357-3b74-4d39-a54d-b09f3491ab4b_en?filename=EU_Blockchain_Ecosystem_Developments_3.0.pdf) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Blockchain and Distributed Digital Ledger Technologies (RP2025) | Interoperable Europe Portal](https://interoperable-europe.ec.europa.eu/collection/rolling-plan-ict-standardisation/blockchain-and-distributed-digital-ledger-technologies-rp2025) - [EU Blockchain Ecosystem latest developments - Country summaries& factsheets - European Commission](https://blockchain-observatory.ec.europa.eu/news/eu-blockchain-ecosystem-latest-developments-country-summaries-factsheets-2022-09-09_en) - [FATF Issues Comprehensive Guidance on Virtual Asset Recovery](https://www.chainalysis.com/blog/fatf-guidance-virtual-asset-recovery-law-enforcement-november-2025/) - [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [Blockchain Legal Library](https://www.trmlabs.com/blockchain-legal-library) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Global crypto regulation review 2025](https://www.elliptic.co/resources/global-crypto-regulation-review-2025) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [2024 Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information/2024-enforcement-information) - [Liechtenstein Criminal Code (StGB): Excerpts § 5 Mens rea](https://www.unodc.org/cld/uploads/res/document/lie/criminal_code_-_excerpts_in_english_html/Liechtenstein_Criminal_Code_-_Excerpts_in_English.pdf) - [International Criminal Court-Related Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/international-criminal-court-related-sanctions) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/enforcement-actions) - [Signa’s Benko Faces Liechtenstein Fraud, Money-Laundering Probe - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-11/signa-s-benko-faces-liechtenstein-fraud-money-laundering-probe) - [Benko: Liechtenstein prüft Verdacht auf Betrug und Geldwäsche - Bloomberg](https://www.bloomberg.com/news/articles/2024-04-11/benko-liechtenstein-pruft-verdacht-auf-betrug-und-geldwasche) - [Signa’s Rene Benko to Remain in Pre-Trial Detention Amid Fraud Investigation - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-24/signa-s-benko-to-remain-in-detention-amid-fraud-investigation) - [Signa Founder Rene Benko Arrested in Austrian Fraud Probe - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-23/austria-issues-arrest-warrant-for-signa-founder-rene-benko) - [Signa Founder Benko’s Home Raided by Police in Fraud Probe - Bloomberg](https://www.bloomberg.com/news/articles/2024-06-25/signa-founder-benko-s-home-raided-by-police-in-fraud-probe) - [Signa Founder Benko Found Guilty of Hiding Watches in Fraud - Bloomberg](https://www.bloomberg.com/news/articles/2025-12-10/signa-founder-benko-found-guilty-of-insolvency-fraud-standard) - [FinCEN Advisory](https://www.fincen.gov/sites/default/files/advisory/advis19.pdf) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Jurisdictions under Increased Monitoring - 13 June 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2025.html) - [News](https://www.fatf-gafi.org/en/the-fatf/news.html) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures against serious human rights violations and abuses - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/22/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-against-serious-human-rights-violations-and-abuses/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries with concerning restrictive measures in view of the situation Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/high-representative-statement-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-with-concerning-restrictive-measures-in-view-of-the-situation-russia/) - [Sanctions - consilium.europa.eu - European Union](https://www.consilium.europa.eu/en/topics/sanctions/) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of the situation in Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/08/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [Russia’s war of aggression against Ukraine: comprehensive EU’s 14th package of sanctions cracks down on circumvention and adopts energy measures - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2024/06/24/russia-s-war-of-aggression-against-ukraine-comprehensive-eu-s-14th-package-of-sanctions-cracks-down-on-circumvention-and-adopts-energy-measures/) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries with Council Decision concerning restrictive measures in view of the situation in Russia - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-with-council-decision-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [Overview of sanctions and related resources - Finance - European Commission](https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-resources_en) - [EU adopts 19th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-19th-package-sanctions-against-russia-2025-10-23_en) - [Statement by the High Representative on behalf of the EU on the alignment of certain countries concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/11/12/statement-by-the-high-representative-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-russia-s-actions-destabilising-the-situation-in-ukraine/) - [Russia's war against Ukraine: EU sanctions - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Guidance-Beneficial-Ownership-Transparency-Legal- ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.pdf.coredownload.inline.pdf) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [Beneficial Ownership](https://www.fatf-gafi.org/en/topics/beneficial-ownership.html) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [A Toolkit for Beneficial Ownership Transparency and](https://www.unodc.org/rosaf/uploads/documents/Publication/UNDC_BOT_PEP_Toolkit_web.pdf) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [BOI E-FILING - FinCEN](https://boiefiling.fincen.gov/) - [FATF guidance TRANSPARENCY AND BENEFICIAL OWNERSHIP October 2014](https://www.fatf-gafi.org/content/dam/fatf/documents/reports/Guidance-transparency-beneficial-ownership.pdf) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2023](https://www.legislation.gov.uk/uksi/2023/704/made) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [Updated casino guidance to include proliferation financing](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/updated-casino-guidance-to-include-proliferation-financing?es_id=36c0030f75) - [The Money Laundering and Terrorist Financing (High-Risk ...](https://www.legislation.gov.uk/uksi/2023/704/pdfs/uksiem_20230704_en_001.pdf) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024](https://www.legislation.gov.uk/uksi/2024/69/contents/made) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [Mutual Evaluation of Liechtenstein](https://www.fatf-gafi.org/en/countries/j-m/liechtenstein/documents/mutualevaluationofliechtenstein.html) - [Financial Market Authority Liechtenstein | EU Digital Finance Platform](https://digital-finance-platform.ec.europa.eu/cross-border-services/cross-border-testing/participants/financial-market-authority-liechtenstein) - [FINANCIAL ACTION TASK FORCE Mutual Evaluation Report](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER%20Austria%20full.pdf.coredownload.pdf) - [Special Measures | FinCEN.gov](https://www.fincen.gov/resources/statutes-and-regulations/special-measures) - [D SANCTIONS ADVISORY Guidance on Sham Transactions and Sanctions Evasion](https://ofac.treasury.gov/media/935441/download?inline=) - [Russia-related Designations and Designations Updates; Issuance of Russia-related General Licenses; Issuance and Amendment of Russia-related Frequently Asked Questions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20240823) - [Publication of Sanctions Advisory: Guidance on Sham Transactions and Sanctions Evasion | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260331_33) - [Regulations and Guidance](https://ofac.treasury.gov/recent-actions/regulations-and-guidance) - [OFAC Information for Industry Groups | Office of Foreign Assets Control](https://ofac.treasury.gov/additional-ofac-resources/ofac-information-for-industry-groups) - [MONEYVAL / Council of Europe (adopted by FATF)](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MONEYVAL-Mutual-Evaluation-Liechtenstein-2022.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [U.S. Department of the Treasury, OFAC](https://ofac.treasury.gov/recent-actions/20240612) - [U.S. Department of the Treasury, OFAC](https://ofac.treasury.gov/media/935441/download?inline=) - [European Commission](https://finance.ec.europa.eu/news/next-generation-fiunet-2025-02-04_en) - [Bloomberg](https://www.bloomberg.com/news/articles/2024-04-11/signa-s-benko-faces-liechtenstein-fraud-money-laundering-probe) - [European Commission](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Council of the European Union (Consilium)](https://www.consilium.europa.eu/en/press/press-releases/2025/09/04/high-representative-statement-on-behalf-of-the-eu-on-the-alignment-of-certain-countries-concerning-restrictive-measures-in-view-of-the-situation-in-russia/) - [UNODC (UNCAC Country Review Mechanism)](https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/Liechtenstein_Final_Report.pdf) - [Financial Market Authority Liechtenstein](https://www.fma-li.li/en/) Coverage gaps fim-int-2026-07-05-G001: Granular 2025-2026 FMA enforcement-… fim-int-2026-07-05-G001: Granular 2025-2026 FMA enforcement-action data (fines, supervisory measures) specific to Liechtenstein is not available in Tier 1-3 open sources, limiting independent verification of MONEYVAL MER remediation progress. [resolved] fim-int-2026-07-05-G002: No EEA Joint Committee decision tex… fim-int-2026-07-05-G002: No EEA Joint Committee decision text or timeline confirming Liechtenstein's incorporation of the AMLR, 6AMLD or the AMLA Regulation has been identified, leaving the 6AMLD transposition status for Liechtenstein unestablished this cycle. [resolved] fim-int-2026-07-05-G003: The finalised or published text of … fim-int-2026-07-05-G003: The finalised or published text of the revised Blockchain Act (TVTG) aligning with MiCA has not been identified, limiting assessment of the precise supervisory-divergence window for Liechtenstein-licensed VASPs. [resolved] fim-int-2026-07-05-G004: No UK OFSI designation record namin… fim-int-2026-07-05-G004: No UK OFSI designation record naming a Liechtenstein-domiciled entity has been identified, leaving the UK sanctions-regime dimension of Liechtenstein's exposure unverified relative to the OFAC and EU-aligned tracks. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 sanctions-evasion architecture for Liechtenstein was not actively researched this cycle beyond the standing Yemen/Houthi channel check. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (enabler jurisdictions) and D4 (conflict finance) were not actively researched this cycle given pooled-budget prioritisation toward the bound JID's dominant BO-breach and AML-regime signals. [resolved] fim-int-2026-08-20-G003: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-08-20-G003: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle. [resolved] fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Tier-1 government-portal source was directly retrieved this cycle to corroborate the scale (~31,000 entities) or attribution status of the BO-register breach. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 confirmation (Office of Justice or regierung.li press release) of the BO-register breach scope beyond the ~31,000-entity estimate has been reached this cycle. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 (sanctions), D3 (enabler jurisdictions beyond MONEYVAL recommendation), D4 (conflict finance) and D5 (crypto) yielded no LI-specific material this cycle; coverage was concentrated on the BO-register incident and AML/CFT baseline. [resolved] fim-int-2026-09-05-G003: Tier D jurisdiction checks (KH/LA/M… fim-int-2026-09-05-G003: Tier D jurisdiction checks (KH/LA/MX/CO) could not be actively re-run within the pooled union budget this cycle. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): LI-specific AMLR/6AMLD/AMLA transposition date could not be established this cycle; LI as an EEA-EFTA state incorporates via EEA Joint Committee lag rather than direct EU-27 application. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No conflict-finance (D4) nexus for Liechtenstein was identified this cycle. [resolved] fim-int-2026-09-28-G003: Tier D watch jurisdictions LA, MX a… fim-int-2026-09-28-G003: Tier D watch jurisdictions LA, MX and CO were not reached this cycle due to budget constraint; only KH was actively searched. [resolved] fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G004 ({'scheme': 'financial_integrity', 'value': 'D1'}): The US-sanctions/LI-trust-freeze reporting rests on a single T3 press source; no primary OFAC/OFSI designation instrument was located naming specific LI entities. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary government BuA text retrieved for the national AMLA consultation report; only secondary law-firm commentary available. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): No LI-specific implementing instrument retrieved for the EU high-risk country list update; LI's own alignment mechanism confirmed but the particular update's LI-level transposition not verified. [resolved] fim-int-2026-10-04-G003: D3, D4 and D6 coverage thin this cy… fim-int-2026-10-04-G003: D3, D4 and D6 coverage thin this cycle; no LI-attributable enforcement action or sanctions designation located. [resolved] fim-int-2026-10-11-G001: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-11-G001: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle; research budget was concentrated on the bound jurisdiction LI. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact EEA Joint Committee incorporation date and text for MiCAR into the EEA Agreement beyond the general '24 June 2025' figure was not verified against the EEA Joint Committee's own decision text. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Precise date of the FATF follow-up report determining LI's Recommendation re-ratings was not independently confirmed this cycle. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No AVW/primary government source located for the TGI AG criminal fraud/ML investigation beyond press reporting; confidence capped at Probable. [open] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Global Tier-D watch (Cambodia, Laos, Mexico, Colombia) and Russian sanctions-evasion/Yemen-Houthi sweeps were not run under the JID-bound union dispatch this cycle. [open] fim-int-2026-10-25-G001: D1 Houthi/Yemen-specific UN Panel/O… fim-int-2026-10-25-G001: D1 Houthi/Yemen-specific UN Panel/OFAC/OFSI check was not run against Liechtenstein this cycle given the pooled search budget. [open] fim-int-2026-10-25-G002: D3 enabler-jurisdiction finding spe… fim-int-2026-10-25-G002: D3 enabler-jurisdiction finding specific to the TCSP sector in Liechtenstein was not located this cycle. [open] fim-int-2026-10-25-G003: D4 conflict-finance finding specifi… fim-int-2026-10-25-G003: D4 conflict-finance finding specific to Liechtenstein was not located this cycle. [open] fim-int-2026-10-25-G004: EEA Joint Committee incorporation d… fim-int-2026-10-25-G004: EEA Joint Committee incorporation decision date for the AMLR/6AMLD/AMLA package specific to Liechtenstein was not confirmed against a primary source this cycle. [open] FIM-GAP-001 (D3): MONEYVAL's 2022 MER found that although mo… FIM-GAP-001 (D3): MONEYVAL's 2022 MER found that although monetary fines had increased since 2019, it was 'not possible to conclude that effective, proportionate, or dissuasive sanctions have been applied by the FMA,' with the FMA relying mostly on remedial supervisory measures and enforcement action against the TCSP sector specifically identified as inadequate. FIM-GAP-002 (D2): The MER identified that simplified/enhance… FIM-GAP-002 (D2): The MER identified that simplified/enhanced CDD exemptions are applied to certain sectors, including investment funds, 'not supported by a country assessment of risk,' despite the exemption being 'used extensively' within the financial centre. FIM-GAP-003 (D6): Publicly available reporting on individual… FIM-GAP-003 (D6): Publicly available reporting on individual FMA enforcement actions, fines, or supervisory measures specific to 2025-2026 is sparse in open-source/Tier-2/Tier-3 media relative to larger financial centres, limiting independent verification of post-MER remediation progress absent direct FMA/MONEYVAL follow-up publication. ## Evidence #### Confidence-tiered claims TVTG registrations for activities subject to MiCAR authorisation expired 2 July 2026 under MiCAR Art. 63/143(3), implemented via the EEA-MiCA-Durchführungsgesetz; providers must hold MiCA authorisation to continue those services. [[Source 1]](#sec-sources) Probable · 1 source Consultation report adopted 3 March 2026 for a new national Anti-Money Laundering Act (AMLA) that will repeal the Due Diligence Act (SPG); occasional-transaction CDD threshold set to fall from CHF 15,000 to CHF 10,000 ahead of the EU AMLR's 10 July 2027 application date. [[Source 1]](#sec-sources) Probable · 1 source EU delegated regulations (EU) 2026/46 and (EU) 2026/83 added Russia, Bolivia and the British Virgin Islands (and removed Burkina Faso, Mali, Mozambique, Nigeria, South Africa, Tanzania) from the AML high-risk third-country list effective 29 January 2026; LI's FMA-supervised obliged entities apply enhanced due diligence to counterparties in listed countries. [[Source 1]](#sec-sources) Probable · 1 source Governing instrument is the Due Diligence Act (SPG) plus the Due Diligence Ordinance (SPV); supervisory authority and enforcement is the FMA; central reporting body is the Stabsstelle FIU (governed by the FIUG); LI implements the 4th/5th EU AML Directives and Wire Transfer Regulation (EU) 2015/847 via EEA incorporation. MONEYVAL's 5th-round report (29 June 2022) placed LI in the 'regular follow-up' track, held by only five MONEYVAL jurisdictions. [[Source 1]](#sec-sources) Probable · 1 source External access resumed 5 October 2026 only via in-person identification at the Giessen Service Centre, Vaduz, with reduced technical functions, following a cyberattack on 29/30 July 2026 affecting ~31,000 legal entities' BO data. [[Source 1]](#sec-sources) Probable · 1 source GDPR Art. 33/34 breach notification triggered by the VwbP cyberattack; individual notification of affected legal entities ongoing since 4 August 2026. [[Source 1]](#sec-sources) Probable · 1 source Recommendations 2, 12, 18, 22, 25, 26, 27 upgraded from Partially Compliant to Largely Compliant; Recommendations 14, 32, 33 upgraded from Partially Compliant to Compliant. [[Source 1]](#sec-sources) Probable · 1 source Three Swiss-linked crypto firms obtained MiCA CASP authorisation from Liechtenstein's FMA in June 2026, continuing LI's role as an early-mover MiCA gateway. [[Source 1]](#sec-sources) Probable · 1 source FMA ordered TGI AG to cease distribution of gold-purchase-linked products and stop unauthorised deposit-taking; Appeals Commission partially upheld suspensive-effect relief on 12 August 2026. [[Source 1]](#sec-sources) Probable · 1 source Immediate cessation of distribution/public offer of three deposit-like products ('Customer Basic 2%', 'Sales Premium', 'Sofortrabatt'), ordered 26 May 2026; order partially upheld by FMA Appeals Commission 12 August 2026 [[Source 1]](#sec-sources) Probable · 1 source TGI AG ceased Liechtenstein operations 31 July 2026 and relaunched as Trust Gold International Ltd in Mauritius following FMA enforcement and a criminal fraud/money-laundering investigation (office raid, June 2026) [[Source 1]](#sec-sources) Probable · 1 source Suspected fraud and money laundering under investigation following a June 2026 office raid on TGI AG's Vaduz premises [[Source 1]](#sec-sources) Uncertain · 1 source FMA published a warning 8 October 2026 against financial-partner-ltd.com, a clone site unlawfully using the identity of the genuine, registered Financial Partners FP Ltd (Vaduz, FL-0002.155.326-0) [[Source 1]](#sec-sources) Probable · 1 source On the regular (not enhanced) MONEYVAL follow-up process since its 5th round report, 29 June 2022; 6th round evaluation not scheduled until October 2029 [[Source 1]](#sec-sources) Probable · 1 source AMLA published final drafts of three regulatory technical standards on 1 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Consultation report adopted 3 March 2026; commencement pending EEA Joint Committee decision to incorporate the 6th AML Directive [[Source 1]](#sec-sources) Probable · 1 source Voluntarily waived its VT-custodian registration under TVTG Art. 12(1) jo Art. 2(1)(n), effective 24 September 2026; registration expired under Art. 20(1)(a) TVTG, announced by FMA 14 October 2026 [[Source 1]](#sec-sources) Probable · 1 source ~31,000 legal entities' BO data exfiltrated overnight 29-30 July 2026 [[Source 1]](#sec-sources) Probable · 1 source No evidence of alteration or deletion of BO register data; banking sector unaffected [[Source 1]](#sec-sources) Probable · 1 source Consultation report adopted 3 March 2026; transposes AMLD6; repeals SPG [[Source 1]](#sec-sources) Probable · 1 source Regular (non-enhanced) follow-up track, one of only five MONEYVAL jurisdictions with that result; no near-term re-evaluation due (next onsite 2030) [[Source 1]](#sec-sources) Probable · 1 source TVTG registrations for MiCA-scope activities expired 2 July 2026 [[Source 1]](#sec-sources) Probable · 1 source CHF 590,000 in final fines across 17 proceedings, 13 for Due Diligence Act violations [[Source 1]](#sec-sources) Probable · 1 source regular follow-up, fifth-round mutual evaluation, most recently reported October 2025 [[Source 1]](#sec-sources) Probable · 1 source Breach confirmed 3 August 2026; records on approximately 31,000 legal entities exfiltrated, reportedly exploiting a weakness MONEYVAL had flagged. [[Source 1]](#sec-sources) Probable · 1 source TVTG registrations for MiCAR-covered activities expired as of 2 July 2026, following EEA MiCA Implementation Act (EWR-MiCA-DG) entry into force 1 February 2025. [[Source 1]](#sec-sources) Probable · 1 source