We would like to inform you about the recent adoption of Regulation (EU) 2023/1113 (Transfer of Funds Regulation, TFR) by the Landtag on December 5, 2024, and its entry into force in Liechtenstein on February 1, 2025.

TFR (Travel Rule) in Liechtenstein
The TFR introduces uniform standards for regulating crypto-asset transactions across the EEA. It is the EU implementation of the "travel rule" required by the FATF, which was already addressed in Liechtenstein in 2021 through national regulations (see FMA Guideline 2021/18 on obligations for VT transfers).

Additionally, the TFR extends enhanced due diligence requirements for correspondent banking relationships to providers of crypto-asset services. Starting February 1, 2025, the TFR will directly apply to crypto-asset service providers in Liechtenstein, with implementation and compliance monitored by the FMA through on-site inspections.

EBA Guidelines
Alongside the TFR’s directly applicable provisions, crypto-asset service providers must also comply with the EBA Guidelines (EBA/GL/2024/11) on information requirements for fund transfers and specific crypto-asset transfers ("Travel Rule Guidelines"). The FMA has submitted a corresponding compliance notification to the EBA regarding these guidelines.

The guidelines include detailed requirements for capturing and transmitting personal data, handling missing information, and implementing risk mitigation measures for transfers involving self-hosted wallets (also known as non-custodial wallets).

RBA Reporting Form by the FMA
Note for RBA Reporting on Risk Assessment for VT Service Providers:
The terminology adjustments made in Guideline 2018/7 on March 14, 2024, have not yet been incorporated into the "RBA Reporting Form for Risk Assessment under SPG – VT Service Providers." You may continue to submit your reports as in previous years, with no changes required on your part.

EBA Consultation on CCP RTS
We would also like to draw your attention to the public consultation by the EBA on the "Draft RTS amending Commission Delegated Regulation (EU) 2018/1108", which is open until February 4, 2025. The proposed amendment will require CASPs to establish Central Contact Points (CCPs) in other EU/EEA member states if they meet the criteria outlined in the RTS.

Further Information
For additional details, we recommend reviewing the EBA's overview of anti-money laundering (AML) and counter-terrorism financing (CFT) in the crypto sector. This includes key information on the interaction between MiCAR and TFR and relevant transitional provisions.

If you have any questions, please do not hesitate to contact us.