FMA Liechtenstein Issues Dismissal Notice for CI Fund Services AG

Liechtenstein's financial regulator, the Financial Market Authority (FMA), has published a formal dismissal notice concerning CI Fund Services AG. For accounting firms, fund auditors, and CFOs with exposure to Liechtenstein-domiciled fund structures, this notice is a direct prompt to verify the current licence status of any service providers in the chain before the next reporting cycle.

What the FMA Notice Confirms

The FMA published the notice on 26 June 2026 under its official news channel. The regulator's dismissal notices carry formal legal weight under Liechtenstein's financial services framework: they signal that a supervised entity has been removed from an authorised position, whether as a licensed firm, a responsible manager, or both. The FMA has not, at the time of publication, released a detailed statement of reasons beyond the notice itself.

This action follows an earlier licence revocation by the FMA against CI Fund Services AG. Taken together, the two steps represent a complete regulatory exit of the firm from the Liechtenstein supervised perimeter. You can read the background on the revocation in our earlier coverage of the FMA Liechtenstein revokes CI Fund Services AG licence.

Why This Matters for Fund Accountants and Auditors

Fund service providers in Liechtenstein frequently operate within EU-passported structures, particularly those serving Luxembourg-domiciled funds under AIFMD or UCITS frameworks. When a service provider loses its authorisation, downstream obligations land on the fund itself, its board, its auditors, and the delegating management company.

Auditors in particular face a specific risk: if a fund's annual accounts or interim valuations relied on work performed by CI Fund Services AG during any period now under question, those engagements need fresh scrutiny. Reliance on outputs from an entity whose authorisation has since been withdrawn can affect the defensibility of audit conclusions.

For firms advising Luxembourg-based fund structures with Liechtenstein-side service arrangements, this is a moment to run a quick counterparty check. Our coverage of CSSF warnings on identity theft affecting Luxembourg fund managers is a useful parallel: regulators across the region are tightening scrutiny of the full service-provider chain.

Immediate Compliance Steps

Firms should consider three actions without delay. First, confirm whether any current fund mandates used CI Fund Services AG for administration, NAV calculation, transfer agency, or any other regulated function. Second, check whether any contractual or regulatory reporting obligations require notification to investors or the competent authority when a service provider loses its licence. Third, assess whether substitute arrangements are in place or need to be sourced, and document that assessment as part of the fund's ongoing governance record.

AML and KYC files also need attention. If CI Fund Services AG held any customer-facing or counterparty role, its removal from the supervised perimeter may affect the adequacy of existing due diligence records. Firms operating under AMLD frameworks should treat this as a trigger event for a file review.

Broader Regulatory Context

The FMA has been consistent in its enforcement posture across the past year. Liechtenstein's EEA membership means its supervised entities can passport services across the single market, so enforcement actions there carry weight beyond the principality itself. Accounting firms that maintain cross-border fund client rosters need a process for monitoring FMA notices alongside those from CSSF, MFSA, and equivalent EEA authorities.

Building that monitoring into a standard compliance calendar, rather than relying on ad hoc news checks, is the cleaner operational answer. This is especially true as MiCA and related EU frameworks raise the bar for ongoing licence verification across the crypto-asset and digital fund space. For broader context on the EU regulatory direction, see our article on crypto compliance reporting.

FAQs

What is the difference between an FMA licence revocation and a dismissal notice?

A revocation withdraws the authorisation granted to the firm as an entity. A dismissal notice typically removes a specific approved person or the firm from a supervised role or register. Both have immediate legal effect under Liechtenstein law, and both mean the affected party can no longer carry out the relevant regulated activities.

Do Luxembourg funds need to notify the CSSF if a Liechtenstein service provider loses its FMA authorisation?

It depends on the fund's prospectus, the delegation agreement, and the specific CSSF circulars applicable to the fund type. In many AIFMD and UCITS structures, material changes to service providers trigger a notification or prior-approval obligation. Firms should check the relevant circular and the fund's governing documents promptly.

What should auditors do if they relied on work produced by CI Fund Services AG?

Auditors should assess whether that reliance remains appropriate given the changed regulatory status of the firm. Where the work relates to a current or upcoming audit period, additional procedures may be needed to corroborate findings that were previously supported by that service provider's outputs.

Is Liechtenstein inside the EU regulatory perimeter?

Liechtenstein is not an EU member state, but it is part of the European Economic Area. This means FMA-supervised entities can passport regulated services into EU member states, and EU directives such as AIFMD and MiCA apply in Liechtenstein via EEA incorporation. Enforcement actions by the FMA therefore have practical consequences for fund structures across the single market.

Where can I monitor FMA enforcement notices on an ongoing basis?

The FMA publishes enforcement and supervisory notices directly on its official website at fma-li.li. Firms should either subscribe to FMA alerts or incorporate its news feed into their regulatory-monitoring processes alongside alerts from other EEA supervisors.

Source: FMA Liechtenstein