Liechtenstein’s Travel Rule: What TT Service Providers Need to Know
Liechtenstein has implemented robust Travel Rule obligations aligned with FATF Recommendation 16, embedding them into its national AML/CFT regime.
The Travel Rule in Liechtenstein applies to Trustworthy Technology (TT) transfers and imposes stringent data-sharing, verification, and due diligence requirements on TT service providers. With a CHF 1 threshold, compliance is effectively required for almost all token transfers
Understanding the Regulatory Obligations for TT Service Providers
Scope of the Travel Rule in Liechtenstein
All Trustworthy Technology (TT) transfers fall under the Travel Rule; accordingly, the Travel Rule applies to all TT service providers offering the following services:
- “‘Token issuer’: a person who publicly offers tokens which are not covered by Regulation (EU) 2023/1114, either on his own behalf or on behalf of a contracting authority;
- ‘Token producer’: a person who puts tokens into circulation on behalf of clients and ensures the technical requirements for the effective disposal of tokens vis-à-vis third parties;
- ‘Tokenization service provider’: a person who puts tokens into circulation on behalf of clients and ensures the legal and technical requirements for the effective representation and transfer of rights by tokens vis-à-vis third parties;
- ‘VT custodian’: a person who holds VT keys or tokens that are not within the scope of Regulation (EU) 2023/1114 and do not constitute financial instruments as defined in Article 4(1)(15) of Directive 2014/65/EU on behalf of principals;
- "physical validator": a person who ensures the contractual enforcement of rights to property represented in tokens within the meaning of property law on VT systems;
- "VT verification body": a person who verifies the legal capacity and the prerequisites for disposing of a token;
- "VT price service provider": a person who provides aggregated price information to users of VT systems based on buy and sell offers or completed transactions;
- "VT identity service provider": a person who identifies the owner of a token and records it in a directory.”
Download Liechtenstein's Travel Rule Overview
Obligations of Ordering TT Service Providers
The ordering TT service provider must collect and transmit the required Travel Rule data to its beneficiary for all transfers exceeding the CHF 1 threshold.
It is the responsibility of the ordering TT service provider to ensure that the collected data is correct and complete. In the event of missing Travel Rule data, the ordering TT service provider must ensure its transmission within 3 working days.
Enhanced due diligence must be applied where the counterparty TT service provider is located in a high-risk jurisdiction. [Article 23 DDO]
Required Travel Rule Data
Ordering TT service providers must collect and transmit the information below to the beneficiary TT service provider:
- originator’s name;
- originator’s account number (where an account is used);
- originator’s address, official personal document number, customer identification number, or date and place of birth;
- beneficiary’s name;
- beneficiary’s account number.
Where the transfer is not linked to a TT account, a unique transaction code must be transmitted in place of the account number.
Where a domestic TT service provider transacts with a large foreign VASP that has not yet implemented the Travel Rule, it must attempt to exchange the required information. Any refusal by the counterparty must be documented.
Obligations of Beneficiary TT Service Providers
Beneficiary TT service providers must identify and verify their counterparty’s identity. If the counterparty is based in a high-risk jurisdiction, enhanced due diligence must be applied.
Additionally, beneficiary TT service providers must establish risk-based procedures to detect whether Travel Rule information is missing, incomplete, or delayed.
How Beneficiary TT Service Providers Must Handle Missing Travel Rule Information
If the transaction is missing Travel Rule data or the data set is incomplete, the beneficiary TT service provider should reject or suspend the transfer.
Should the data not be in line with Article 23d, the beneficiary TT provider must notify its counterparty and request the missing information, which must be provided within 3 working days. If the data is not provided within this period, the transfer must be rejected or returned. If rejection is not possible, the tokens must be re-transferred.
A TT transfer may only be completed once a complete Travel Rule data set has been received.
If an ordering TT service provider repeatedly fails to provide compliant information, the beneficiary TT service provider may reject all future transactions and restrict further business relationships.
Self-Hosted Wallets
Self-hosted wallets fall within Liechtenstein’s Travel Rule framework.
When dealing with self-hosted wallets, TT service providers must apply enhanced due diligence, including:
- clear assignment of the wallet to the beneficiary, using proof of ownership mechanisms such as a Satoshi Test or cryptographic signature (e.g. AOPP);
- transaction analysis using blockchain investigation tools;
- enhanced information on the source of funds for incoming transactions;
- a full KYC check on the client
In Conclusion
Liechtenstein’s Travel Rule regime imposes strict obligations on both ordering and beneficiary TT service providers.
The Liechtenstein framework exceeds FATF standards by incorporating near-zero thresholds, robust counterparty due diligence, stringent handling of missing data, and enhanced controls for self-hosted wallets.
21 Travel Rule and the Liechtenstein Travel Rule
21 Travel Rule helps TT service providers in Liechtenstein meet all FMA, DDA, DDO, and TVTG requirements.
The solution enables automated counterparty discovery, preventing TT service providers from receiving assets from unknown counterparties. It ensures compliant data exchange, reducing operational risk and preventing rejected or delayed transfers.
With integrated self-hosted wallet verification, blockchain analytics, and secure data management, 21 Travel Rule allows Liechtenstein TT service providers to operate confidently while maintaining full compliance with local and international standards.
Become Travel Rule Compliant with 21 Analytics
Further Reading
Article 12 of the Due Diligence Act
Article 23 of the Due Diligence Ordinance
Disclaimer
This material is provided for educational and informational purposes only and is not intended to be a substitute for professional advice or detailed research.
