Feedback letter AML/CFT inspections 2024

In the 2024 inspection cycle, the FMA once again carried out numerous inspections regarding compliance with the provisions of the Liechtenstein AML Act. The inspections are risk-based and always include a review at institutional/organisational level (‘firm review’) as well as a review of individual customer files (‘file review’) in order to check whether all legally required due diligence measures have been taken for a specific customer.

The FMA has summarised the most important findings from the inspections carried out in 2024 for the banking, life insurance, asset management, fund and fiduciary sectors and illustrated some of them using examples of good and bad practices found.

A total of 134 obliged persons under the AML Act were subject to an independent on-site inspection by the FMA in 2024. The feedback letters contain, in particular, findings regarding the structural and procedural organisation, risk-adequate monitoring, the processes regarding suspicious activity reports and inspection activities as well as reporting obligations in connection with restrictive measures (sanctions).