LIECHTENSTEIN Law and Practice Contributed by: Bernhard Rankl, Moritz Blasy and Nicolai Binkert, Schurti Partners Attorneys at Law Ltd
Single Rulebook Regulation (Regulation (EU) 2024/1624; AMLR) This regulation, which will come into force in July 2027, aims to streamline and standardise anti- money laundering rules across the EU/EEA by moving from a directive-based approach to a regulation-based approach, which will be direct - ly applicable in all EU and EEA member states. This Regulation complements the other two components of the EU AML package described above. The AMLR shall apply from 10 July 2027. Crypto-Assets Regulation (EU) 2023/1114 on markets in crypto- assets (MiCAR) entered into force on 29 June 2023 and will be fully applicable in the EU from 30 December 2024. The aim of this regulation is to create a harmonised legal framework for persons active in the primary and secondary markets for crypto-assets. MiCAR will become directly applicable in Liechtenstein as soon as the corresponding decision of the EEA Joint Committee to incorporate the regulation into the EEA Agreement enters into force. The nec - essary transposition into Liechtenstein law will take place through the Act on the Implementa - tion of Regulation (EU) 2023/1114 on Markets in Crypto Assets (EWR-MiCAR-Durchführungsge - setz, EWR-MiCAR-DG), which is currently in the legislative process and is expected to enter into force on 1 February 2025.
the next three years. Key changes include the introduction of the concept of corporate crimi - nal liability for AML offences, which means that banks themselves can be held liable for money laundering activities in addition to individuals. AMLD VI also increases the penalties for AML violations, with higher fines and longer prison sentences for those involved in money launder - ing. EU AML Authority Regulation (Regulation (EU) 2024/1620; AMLAR) The EU’s AML Action Plan aims to create a sin - gle regulatory framework for AML across the EU and EEA. This includes the establishment of a new European Anti-Money Laundering Authority (AMLA), which will have direct supervisory pow - ers over certain high-risk entities and provide centralised oversight of the AML regime. Liech - tenstein banks will be affected by the centralisa - tion of AML supervision, and the FMA Liechten - stein will need to coordinate closely with the new AMLA to ensure compliance. The AMLA shall apply from 1 July 2025.
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