Regulation Liechtenstein
The Due Diligence Act (SPG) in Liechtenstein
Updated: · Leutrim Miftaraj, FLIORE · Editorial standards · Other languages: Deutsch · Français · Español
Short answer
Liechtenstein's Due Diligence Act (SPG) obliges banks, trustees, asset managers and other obliged entities to identify contracting parties, establish beneficial owners, draw up a business profile, monitor business relationships on a risk-based basis and document everything. Suspicions are reported to the Financial Intelligence Unit (SFIU). Supervision lies with the Financial Market Authority Liechtenstein (FMA).
Who is an obliged entity
Besides banks and insurers, the obliged entities include in particular trustees and trust companies, asset management companies, lawyers for certain activities, and persons who act as officers of legal entities. For family offices in Liechtenstein, the decisive question is whether they provide such services for third parties. Implementing provisions are contained in the Due Diligence Ordinance (SPV).
The core obligations
- Identifying the contracting party and verifying their identity.
- Establishing and verifying the beneficial owners.
- Drawing up a business profile with the source of assets and the purpose of the relationship.
- Risk-based monitoring of the business relationship for its entire duration.
- Documentation and retention of records.
- Reporting to the SFIU in case of suspected money laundering, predicate offences or terrorist financing.
The business profile
The business profile is a distinctive feature of the Liechtenstein regime in its depth: it records who stands behind the relationship, where the wealth comes from, which transactions are expected and what the structure is for. It must be kept up to date and serves as the benchmark for monitoring. For foundations and trusts it includes the beneficiaries or classes of beneficiaries and the persons with control rights.
The trustee as an officer
Legal entities without commercial activity in Liechtenstein, such as many foundations and establishments, must have at least one officer who holds a licence under the Trustee Act (Art. 180a of the Persons and Companies Act, PGR). As a result, almost every structure involves an obliged entity that fulfils the SPG obligations – and that expects complete, current documents from the family office.
Working with the trustee
- Provide complete information on the founder, beneficiaries and controlling persons.
- Document the source of assets with evidence.
- Report changes such as a change of residence, new beneficiaries or deaths immediately.
- Actively support periodic updates of the business profile.
- Keep documents consistent for all banks of the structure.
In FLIORE
FLIORE manages Liechtenstein foundations, establishments and trusts as mandates with roles, identity and tax data, assets and documents. The KYC package compiles documents for trustees and banks into a single PDF.
At a glance
| Act | Due Diligence Act (SPG) with Due Diligence Ordinance (SPV) |
|---|---|
| Supervision | Financial Market Authority Liechtenstein (FMA) |
| Reporting office | Financial Intelligence Unit (SFIU) |
| Distinctive feature | Business profile as the central document |
Terms on this page
- Beneficial owner
- The natural person who ultimately owns or controls a company, foundation or trust, or on whose behalf a transaction is carried out.
Frequently asked questions
Does the SPG apply to a single family office in Liechtenstein?
That depends on its activities. If it manages only its own family's wealth without obliged activities for third parties, it may fall outside the act. The classification should be clarified with the FMA or specialists.
How does the SPG differ from the Swiss AMLA?
Both follow the FATF standards. As an EEA state, Liechtenstein is also bound by the EU anti-money laundering directives; terms and detailed rules differ.
What must a trustee establish for a foundation?
The founder, members of the foundation board, the protector, beneficiaries or classes of beneficiaries and other persons with control.
Where are suspicions reported?
To the Financial Intelligence Unit (SFIU) in Vaduz.
Which documents does the trustee expect from the family office?
Identity documents and residence details of the beneficial owners, evidence of the source of assets, information on the purpose of the structure and the expected transactions, and every change concerning beneficiaries or controlling persons.
Sources
- Liechtenstein law gazette – gesetze.li
- Financial Market Authority Liechtenstein (FMA)
- National Administration of Liechtenstein – Financial Intelligence Unit (SFIU)
This page provides orientation and does not replace legal or tax advice. The cited legal sources in their applicable version are authoritative.
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