LIECHTENSTEIN Trends and Developments Contributed by: Thomas Plattner and Fabian Jenny, Ospelt & Partners Attorneys at Law Ltd.
defined as the natural person on whose behalf the transaction ultimately occurs (Article 2 (1)(e), SPG). Complex ownership structures – common in high‑val - ue art – require enhanced measures (Article 7 (2), SPG). Market participants must maintain comprehen - sive transaction‑related records (Article 2 (1)(q), SPG). Transition to the EU Single Rulebook (Regulation (EU) 2024/1624) Liechtenstein is transitioning to the EU AML Package, notably Regulation (EU) 2024/1624 (AMLR), which harmonises customer due diligence and beneficial ownership rules across the EEA. Although AMLR is effective, most obligations apply from 10 July 2027 (Article 90, AMLR). During 2026, market participants must align internal policies to prepare for these requirements. Strategic shifts: from “art objects” to “cultural property” Under the AMLR, the regulated sector shifts toward dealers and intermediaries trading in “cultural proper - ty”, defined by Annex I of Regulation (EC) No 116/2009 (Article 2 (1)(56), AMLR). Items must typically be at least 50 years old. Works still owned by their creators – ie, contemporary primary‑market art – are generally excluded unless they qualify as high‑value goods. The regulatory focus therefore moves toward antiqui - ties and secondary-market works. Enhanced institutional oversight and sanctions compliance The Authority for Anti‑Money Laundering and Coun - tering the Financing of Terrorism (AMLA) began oper - ations on 1 July 2025 (Regulation (EU) 2024/1620). AMLA will co-ordinate supervisors and support FIUs. Under Article 9 (1)(b), AMLR, market participants must implement systems to prevent sanctions evasion, including continuous screening of customers and beneficial owners. Failure to maintain such defences may lead to administrative penalties regardless of whether a sanctions breach occurs.
Cash payment limits and enforcement thresholds The AML Package introduces an EU‑wide EUR10,000 cash payment limit (Article 80 (1), AMLR), applicable to single or linked transactions. The FMA will intensify oversight during 2026, and vio - lations under SPG – such as failures to identify ben - eficial owners or maintain records – can result in fines up to CHF200,000 (Article 31, SPG). Early adoption of EU‑mandated data‑centric reporting is essential for maintaining compliance. Modernisation of Cultural Property Protections (KGG) Liechtenstein’s Cultural Property Act (KGG; LGBl 2016, No 270) and Cultural Property Protection Ordi - nance (KGSV; LGBl 2021, No 133) provide the basis for protecting national heritage. Owners of registered items must give 14 days’ notice before any physi - cal alteration or change of ownership (Article 35 (1), KGG). Amendments introduced on 1 January 2026 (LGBl 2025, No 395 and VStG; LGBl 2025, No 375) updated the enforcement process, routing appeals to the Appeals Commission for Administrative Affairs. Cultural Property Protection Network and emergency planning The KGS‑Verbund (Cultural Property Protection Net - work) is a rapid‑response body composed of cultural institutions and specialists. Owners must implement preventive safety measures, including an emergency plan based on a mandatory security report and risk analysis. These plans co-ordinate fire brigade actions and provide precise handling instructions for first responders. Security documentation and technical requirements Under the KGSV, the Office of Culture sets the techni - cal standards for security documentation. For 2026, high‑fidelity 3D scanning is the operational stand - ard for objects of national importance. These digital records support both compliance and potential res - toration. Strategic development: Kulturstrategie 2025+ Work is underway on a comprehensive Kulturstrat- egie 2025+ , initiated on 9 September 2025. A steering committee aims to complete the strategy by the end
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