LIECHTENSTEIN Trends and Developments Contributed by: Christian Inmann and Markus Stelzl, Inmann Stelzl & Partner Attorneys at Law Partnership
development and use of AI systems, based on a risk- based approach. Financial services are among the sectors where AI is widely used, in particular in credit assessments, fraud and AML detection, onboarding and customer service. While the text is extensive, its key implication for fintechs is that high-risk AI sys - tems (those that have significant effects on individuals or markets) will be subject to stringent requirements relating to transparency, data governance, human oversight and risk mitigation. As both fintechs and legacy financial institutions scale their use of AI technologies, the AI Act creates a level playing field, where operational and compliance con - trols around AI are no longer optional features, but mandatory governance elements. The AI Act constitutes a comprehensive and bind - ing regulatory framework for artificial intelligence. From 2026 onwards, its core operational provisions will apply in full, with far-reaching consequences for banks, leasing companies, financial service providers and debt collection firms. In the financial sector, the regulation directly affects a wide range of AI-driven systems, particularly those used for creditworthiness assessments, automated credit decisions, fraud detection, customer interaction and debt recovery processes. The AI Act reflects a fundamental regulatory shift. Artificial intelligence is no longer viewed merely as a technological tool that enhances efficiency, but as a potential source of systemic, consumer-related and ethical risk. As a result, the regulation introduces bind - ing requirements that go far beyond traditional IT gov - ernance and directly affect core business processes in financial services. The new EU anti-money laundering package Europe’s Anti-Money Laundering (AML) Package rep - resents one of the most significant reforms in AML/ CFT regulation in decades. Adopted in 2024 and pub -
lished in the Official Journal of the European Union on 19 June 2024, the package is designed to har - monise AML rules across all EEA member states, replacing the previous directive-based system with a uniform set of directly applicable regulations, a new EU Authority for Anti-Money Laundering (AMLA) and a Single Rulebook Regulation (AMLR). For Liechtenstein, full implementation and applicability of the AML Package is anticipated by mid-2027. This new regime aims to strengthen risk-based controls across financial and non-financial sectors, including crypto-asset service providers that fall under MiCAR rules. AMLA will play a central role in coordinating consistent application, issuing technical standards and supervising high-risk entities within the European AML framework. The reform reflects a broader evolution in AML expec - tations: automated systems, transaction monitoring, and governance frameworks which must be resilient, auditable and effective from “day one”, rather than aspirationally compliant. Conclusion: Regulation as a Strategic Reality The combined weight of PSD3, the Digital Services Act, the AML Package, MiCAR, DORA, the TVTG and the AI Act represents a decisive shift in European reg - ulation. The focus has moved from enabling market entry toward ensuring ongoing operational resilience, governance and accountability. Landscape changes previously seen as compliance challenges are now strategic imperatives: firms that build robust regula - tory frameworks into their core operations can achieve superior trust, long-term stability and cross-border scalability. In Liechtenstein, FMA supervisory practice reflects this direction, emphasising substance over form, operational effectiveness over check-the-box com - pliance, and proactive risk governance as a driver of sustainable innovation.
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