June 24, 2024

A Guide to FATF Travel Rule Compliance in Liechtenstein

A Guide to FATF Travel Rule Compliance in Liechtenstein

  • The FATF Travel Rule applies to all crypto transactions above 1 CHF in Liechtenstein.
  •  To operate legally in Liechtenstein, VASPs must register with the FMA and verify transaction parties' identities.
  • VASPs must use blockchain analytics to verify and monitor transactions, especially with unhosted wallets in Liechtenstein.

Since January 1, 2020, Liechtenstein has enforced the Blockchain Act (TVTG), creating a comprehensive legal structure for cryptocurrencies and related services.

Subsequent amendments to the Due Diligence Act (SPG) and the Due Diligence Ordinance (SPV) have integrated the Financial Action Task Force (FATF)'s crypto Travel Rule

Key Features of the Travel Rule

In Liechtenstein, the Travel Rule obliges VASPs to exchange detailed transaction-related personal information for all virtual asset transfers above the minimum threshold of 1 Swiss Franc (CHF). This includes the full names, wallet addresses, and other identifying information of the transaction's originator and beneficiary.

Compliance Requirements

VASPs in Liechtenstein must register as outlined in the TVTG, with the Financial Market Authority (FMA) having three months to respond to registration applications. All VASPs must also verify the identities of counterpart VASPs, particularly when dealing with high-risk jurisdictions, and implement enhanced due diligence measures. These requirements apply to both domestic and cross-border transfers.

For Originators:

  • Full name
  • Wallet address
  • One of the following: physical address, ID document number, customer identification number, or date and place of birth

For Beneficiaries:

  • Name
  • Wallet address

In case the required Travel Rule data is missing, incomplete, or delayed, the beneficiary VASP must implement risk-based procedures to identify and rectify gaps, potentially suspending or rejecting the transfer until compliance is achieved.

Impact on Cryptocurrency Exchanges and Wallets

In Liechtenstein, VASPs like cryptocurrency exchanges and wallet services must adhere to the Travel Rule, supervised by the Financial Market Authority (FMA). This regulation is crucial for preventing money laundering and terrorism financing.

Here’s what they need to do:

Registration and Licensing

VASPs must register and get licenses as per the Trustworthy Technologies Act (TVTG), with the FMA reviewing and approving these applications. This ensures that all VASPs meet high regulatory standards and contribute to a secure financial system.

Monitoring Transfers

Exchanges must monitor all transactions, especially those involving unhosted wallets that let owners directly control their private keys. This includes collecting extra information on these wallets during high-risk transactions to prevent illegal activities.

For this, VASPs must conduct laser-focused diligence and use blockchain analytics tools to verify the wallets' ownership in transactions. Additionally, transactions involving these wallets must be scrutinized using blockchain analysis tools to ensure they do not facilitate money laundering or terrorist financing.

Risk-Based Policies

Both sending and receiving VASPs need to develop policies tailored for managing transfers involving unhosted wallets. These policies must focus on thorough verification and monitoring to align with local and international regulations.

Global Context

Liechtenstein enforces a low threshold for the Travel Rule, requiring compliance for transactions as small as 1 CHF. This is in contrast to places like the United States, where the threshold is $3,000, and Singapore, where it's S$1,500. The European Union, on the other hand, is exploring the idea of applying the FATF Travel Rule to all crypto transactions, regardless of amount. 

Concluding Thoughts

Since implementing the FATF Travel Rule in 2020, Liechtenstein requires detailed verification for cryptocurrency transactions over 1 CHF. This is in sharp contrast to the higher thresholds in the United States and Singapore and the potential for no minimum in the European Union. Liechtenstein's strict approach aims to safeguard financial transactions and prevent illegal activities like money laundering and terrorism financing within its borders.


1. What is the minimum threshold for the Travel Rule in Liechtenstein?

In Liechtenstein, the FATF Travel Rule applies to all cryptocurrency transactions above 1 Swiss Franc (CHF).

2. What information must VASPs collect and verify under the Travel Rule in Liechtenstein?

VASPs must collect and verify full names, wallet addresses, and additional identifying information such as a physical address, ID document number, customer identification number, or date and place of birth for both originators and beneficiaries in Liechtenstein.

3. How must VASPs handle transactions involving unhosted wallets?

VASPs must use blockchain analytics tools to verify the ownership of unhosted wallets and conduct enhanced due diligence to prevent illegal activities in Liechtenstein.


About Veriscope

Veriscope, the compliance infrastructure on Shyft Network, empowers Virtual Asset Service Providers (VASPs) with the only frictionless solution for complying with the FATF Travel Rule. Enhanced by User Signing, it enables VASPs to directly request cryptographic proof from users’ non-custodial wallets, streamlining the compliance process.For more information, visit our website and contact our team for a discussion. To keep up-to-date on all things crypto regulations, sign up for our newsletter and follow us on X (Formerly Twitter), LinkedIn, Telegram, and Medium.