KYC and AML Compliance in Liechtenstein: The SPG, the New AMLA and What Changes by 2027

Liechtenstein's Due Diligence Act (Sorgfaltspflichtgesetz, SPG) — the backbone of the country's AML regime since it implemented the fourth and fifth EU directives — is being repealed. It will be replaced by two instruments: the directly applicable EU AML Regulation, and a new national Anti-Money Laundering Act (AMLA) transposing the sixth directive. The consultation report on the AMLA was adopted on 3 March 2026, and the practical target date for both is 10 July 2027.

For a Liechtenstein bank, trustee or fiduciary, that is not a renaming exercise. A regulation applies directly rather than through national law, which removes the interpretive layer firms are used to working with — and several concrete obligations tighten at the same time.

1. Who is in scope, and who supervises

The Financial Market Authority (FMA) is the competent authority for licensing and for supervising compliance with due diligence obligations. Obliged entities under the SPG include banks, asset managers, insurers, and — distinctively for Liechtenstein — professional trustees, trust companies and foundation administrators, licensed under the Trustee Act (Treuhändergesetz, TrHG).

That fiduciary sector is why Liechtenstein compliance has a different centre of gravity from Switzerland's or Germany's. The obliged entity is frequently sitting inside the ownership structure it must document, not outside looking in.

2. What the SPG requires today

The current regime will feel familiar to anyone working under a European AML framework: identify and verify the contracting party, establish the beneficial owner, apply enhanced due diligence to higher-risk relationships and politically exposed persons, monitor the relationship on an ongoing basis, and report suspicion to the Financial Intelligence Unit.

For trusts and foundations, establishing the beneficial owner means identifying the settlor, the trustee, the protector, the beneficiaries, and any person exercising effective control — not one name, but a map. We cover the mechanics of that in KYC for trusts, foundations and complex ownership structures.

Liechtenstein also maintains a beneficial ownership register, established under the SPG and aligned to EU directive standards through the EEA Agreement.

3. Why the EEA route matters

Liechtenstein is an EEA member, not an EU member. EU AML law does not apply automatically: it is incorporated through the EEA Agreement and then reflected in national law. Historically that produced a lag between an EU deadline and the Liechtenstein one.

The expectation this time is different. Although the AMLA formally depends on the EEA Joint Committee adopting the sixth directive, practical experience points to both instruments being implemented together by July 2027, regardless of the formal timing. Planning on the assumption of a comfortable EEA delay is the main strategic error available here.

4. What actually changes in practice

The headline items for an obliged entity:

The scope of who is obliged also widens, to include crowdfunding service providers, dealers in precious metals and gemstones, investment migration advisors, football agents, and cultural goods dealers above a CHF 10,000 threshold.

Read the first and last rows together and the direction is unmistakable. An annual review cycle on high-risk clients, against a richer beneficial-ownership dataset, is not a modest increase in workload — it multiplies the number of data points that must be current at any given moment. Firms running periodic reviews on spreadsheets will feel this first. It is the same pressure we describe in perpetual KYC, arriving on a fixed date.

5. The trustee trap: acting in your own name

One change deserves separate attention because it is easy to miss and expensive to get wrong.

Under the new framework, a regulated activity counts as performed by an employee only if it is carried out in the name of and on behalf of the legal entity. If either limb fails, the individual becomes separately subject to regulation.

The obvious case: a trustee who sits on a client company's board in their own name rather than on behalf of the trust company. That is standard practice in Liechtenstein fiduciary work. Under the new reading, it may pull the individual into scope personally, with their own compliance obligations rather than shelter under the firm's licence.

Any Liechtenstein fiduciary should be inventorying board seats and mandates held personally by staff, and deciding before 2027 whether each is held in the firm's name or the individual's. This is a documentation and governance exercise, and it takes longer than it sounds.

6. What to do before July 2027

Map your obligations to the Regulation, not to the SPG. A regulation is applied as written. Internal policies that paraphrase the SPG will need to be rewritten against the new text rather than annotated.

Test whether your review cycle can actually run annually. Take your high-risk client population, divide by twelve, and ask whether that monthly volume is achievable with current staffing and tooling. If the answer is no, the gap is structural.

Audit your beneficial-ownership data for the new fields. Place of birth and document numbers are frequently absent from files opened years ago. Backfilling across an existing book is a project, not a task.

Inventory personally held mandates (section 5).

Do not wait for the EEA Joint Committee. Prepare for July 2027 and treat any delay as a bonus.

7. Frequently asked questions

Is the SPG being amended or repealed?

Repealed. Its substantive requirements move into the directly applicable EU AML Regulation, while a new national Anti-Money Laundering Act (AMLA) transposes the sixth directive. The consultation report on the AMLA was adopted on 3 March 2026.

When does the new regime apply in Liechtenstein?

The working date is 10 July 2027, when the EU AML Regulation replaces the SPG. Formally the AMLA depends on EEA Joint Committee adoption, but the practical expectation is that both arrive together by that date.

Who supervises AML compliance in Liechtenstein?

The Financial Market Authority (FMA) licenses financial service providers and supervises compliance with due diligence obligations. Professional trustees are additionally licensed under the Trustee Act (TrHG), so 2027 changes will overlap with existing FMA obligations rather than replace them.

How often must high-risk clients be reviewed?

Annually under the new framework, tightened from the current one-to-two-year cycle. This is one of the changes most likely to expose a capacity gap in smaller fiduciary firms.

Does the new regime cover crypto transfers?

Yes. All cryptocurrency transfers require due-diligence screening, replacing today's partial coverage.

8. How Wecan fits

Wecan Copilot is built for the shape of problem this transition creates: a rising number of data points that must be current at all times, across a book of clients with complex ownership structures. Beneficial-ownership information is structured rather than filed, so the new fields are captured as data and not buried in a PDF; screening runs continuously rather than at review time; and every change carries a timestamped audit trail an FMA examiner can follow.

For the Liechtenstein fiduciary sector specifically, the value is in the ownership map. A trust or foundation structure documented once, maintained continuously, and shared with the banks that need it — rather than reconstructed from scratch at each annual review, for each institution separately.

For neighbouring frameworks, see our guides to Swiss AML in 2026 and the EU AML package through a Luxembourg lens.