In late September 2017, Liechtenstein published a ‘Fact Sheet on ICOs’, which stated that “depending on their specification, tokens may constitute financial instruments subject to financial market law. This may include tokens that have characteristics of equity securities or other investments. In principle, activities relating to financial instruments are subject to licensing by the Financial Market Authority (FMA) on the basis of special legislation and may require publication of a prospectus. In all cases, the specific design and de facto function of the tokens are decisive.“ (Source). If a token is identified as a security, it may have to be licensed by the financial market authority, and subject to anti-money laundering and anti-terrorist financing regulations. In reality, there is no regulation on token sales in Liechtenstein yet. Liechtenstein’s Prime Minister proposed in a speech in Mar 2018 to regulate the tax, spending, and issuance of digital currency and also to create advantageous conditions for new fintech businesses, so it is recommended to keep an eye out on upcoming legislation. (Source).

Crypto fund firms may be considered alternative investment fund managers (AIFM), however, an AIFM must have its effective place of management and registered office in Liechtenstein, requiring its managers to move to the vicinity of Liechtenstein. A Liechtenstein AIFM needs a Financial Market Authority-issued license to conduct business. The license is recognized in all Member states of the EEA and entitles the find to distribute alternate investments within the EEA through a statue called the “EEA/EU passport”. The AIFM requires a minimum paid up capital of EUR 125,000. (Source).

Sources:

• Financial Market Authority of Liechtenstein: Fact Sheet on Initial Coin Offerings
• Article: Liechtenstein To Incorporate Crypto Friendly Regulations
• Alternative Investment Funds 2017 - Liechtenstein