Kaiser Partner Privatbank AG Authorized Under MiCAR Art. 60 in Liechtenstein
The Financial Market Authority Liechtenstein (FMA) has granted Kaiser Partner Privatbank AG, headquartered in Vaduz, authorization to provide crypto-asset services under Article 60(1) of Regulation (EU) 2023/1114, the Markets in Crypto-Assets Regulation (MiCAR). The authorization is effective from June 29, 2026. For accounting firms, auditors, and CFOs whose clients operate or transact within the European Economic Area, this is a concrete signal that the post-transitional MiCAR landscape is taking shape faster than many anticipated.
What Article 60 of MiCAR Actually Does
MiCAR Article 60 is the provision that allows credit institutions already authorized under EU banking law to provide crypto-asset services without going through the full crypto-asset service provider (CASP) application process from scratch. Instead, they notify their competent authority, which in Liechtenstein is the FMA, and demonstrate that they meet the relevant organizational and conduct requirements for the specific services they intend to offer.
Why This Route Matters for Banks
For an established private bank like Kaiser Partner Privatbank AG, the Art. 60 pathway is the logical entry point into regulated crypto-asset services. It leverages existing prudential oversight, AML/CFT frameworks, and governance structures rather than building a parallel authorization from the ground up. The bank holds the Liechtenstein registration number FL-0001.018.213-7 and operates under FMA supervision, making the notification route both efficient and credible from a regulatory standpoint.
This also reflects a broader pattern across EEA jurisdictions: traditional financial institutions are not waiting for market conditions to stabilize before seeking MiCAR authorization. They are moving now, in part because the MiCA transitional period expired on July 1, 2026, and operating without authorization after that date is no longer permissible. Our earlier coverage of MiCA transitional period expiry and what mandatory authorization means for CASPs sets out the full timeline and obligations that apply from that date.
Liechtenstein as an EEA MiCAR Gateway
Liechtenstein is an EEA member state, not an EU member state, but it adopts EU financial services legislation through the EEA Agreement. That means MiCAR applies there with full force, and an authorization granted by the FMA carries passporting rights across the EU single market in the same way an authorization from, say, a German or French regulator would.
A Cluster of Authorizations Is Forming
Kaiser Partner Privatbank AG's authorization follows Sygnum Europe AG's earlier MiCAR CASP authorization in Liechtenstein, granted through the standard CASP route rather than the Art. 60 bank notification pathway. Taken together, these two authorizations illustrate that Liechtenstein is emerging as an active node in the EEA's MiCAR authorization landscape, with both purpose-built crypto firms and incumbent private banks choosing the jurisdiction.
For compliance teams advising clients that operate across borders, this matters because a Liechtenstein-authorized entity can passport crypto-asset services into EU member states under MiCAR's home-country control principle. That has direct implications for counterparty due diligence: if a client is transacting with a Liechtenstein-authorized bank offering crypto-asset services, the regulatory backstop is EEA-grade and FMA-supervised.
Implications for Accounting and Compliance Teams
The practical consequences fall into a few distinct areas, each worth reviewing now rather than waiting for a client to raise them.
Counterparty Classification and Record-Keeping
When an authorized CASP or Art. 60 bank provides crypto-asset services, the transaction records it generates carry a different regulatory weight than those from an unregistered or transitional-period entity. Accounting firms handling crypto books for clients that use Kaiser Partner Privatbank AG's services should confirm that the authorization date of June 29, 2026 is correctly reflected in any compliance documentation, client onboarding records, or audit trails tied to transactions from that date onward.
Robust digital asset accounting software needs to accommodate authorization status as a field in counterparty records, not just wallet addresses or transaction hashes. This is the kind of operational detail that separates a well-structured crypto bookkeeping software workflow from one that will create problems at audit.
Travel Rule and AML Obligations
Under MiCAR and the associated Transfer of Funds Regulation (TFR) as it applies to crypto-assets, authorized CASPs and Art. 60 banks are obligated to collect and transmit originator and beneficiary information on crypto-asset transfers above the relevant thresholds. Transactions with Kaiser Partner Privatbank AG from June 29, 2026 onward should be treated as transactions with a regulated counterparty for Travel Rule purposes. Any crypto accounting software used by firms handling these flows should be capable of flagging and recording CASP-to-CASP transfers distinctly from transfers involving unhosted wallets.
The AML risk picture for authorized institutions differs materially from that of unauthorized or transitionally operating entities. Our analysis of Huione Group's illicit marketplace and USDH stablecoin AML risk illustrates, by contrast, what the compliance burden looks like when counterparties lack proper regulatory footing.
Audit and Financial Reporting Considerations
Auditors reviewing financial statements that include crypto-asset holdings or transactions intermediated by authorized MiCAR entities will need to document the regulatory status of those intermediaries as part of the audit file. The authorization date matters: transactions before June 29, 2026 were conducted under whatever pre-authorization arrangements the bank had in place; transactions from that date onward fall squarely under MiCAR's conduct and prudential requirements.
What Firms Should Do Now
Three steps are worth taking immediately.
Update Counterparty Registers
Any firm whose clients transact with Kaiser Partner Privatbank AG should update internal counterparty registers to reflect the MiCAR Art. 60 authorization, the June 29, 2026 effective date, and the FMA as the supervising authority. This is basic hygiene, but it is frequently overlooked when authorizations come through mid-year.
Review Transaction Categorization from June 29 Onward
If your crypto bookkeeping software or manual ledgers categorize transactions by counterparty type, the classification for Kaiser Partner Privatbank AG should shift to reflect authorized CASP status from June 29. This affects how those transactions are treated in AML screening workflows, Travel Rule logs, and potentially in financial statement disclosures depending on the applicable accounting standards.
Monitor the FMA Authorization Register
The FMA publishes its list of authorized entities, and Liechtenstein's approach to MiCAR authorizations is worth tracking for any firm with EEA-facing clients. Additional authorizations, whether through the full CASP route or via Art. 60, will continue to appear as the post-transitional period settles. Building a monitoring habit now avoids the scramble of discovering a counterparty's status changed months after the fact.
FAQ
Article 60 of MiCAR allows credit institutions already authorized under EU or EEA banking law to provide crypto-asset services by notifying their competent authority rather than applying for a separate CASP license from scratch. The bank must still demonstrate it meets MiCAR's organizational and conduct requirements for each service it wants to offer. The FMA granted this authorization to Kaiser Partner Privatbank AG effective June 29, 2026.
Yes. Liechtenstein is an EEA member state and incorporates EU financial services regulation through the EEA Agreement. An authorization granted by the FMA under MiCAR carries passporting rights across EU member states, subject to the standard notification procedures for cross-border or branch activity.
From that date, the bank is an authorized MiCAR entity for the services covered by its Art. 60 notification. Transactions should be recorded accordingly in counterparty registers, AML screening workflows, and Travel Rule logs. The authorization date is the relevant cut-off for regulatory classification purposes.
Under MiCAR and the Transfer of Funds Regulation as extended to crypto-assets, authorized CASPs and Art. 60 banks must collect and transmit originator and beneficiary information on crypto-asset transfers above applicable thresholds. Transactions with Kaiser Partner Privatbank AG from June 29, 2026 should be treated as CASP-to-CASP transfers where relevant, with all associated data collection requirements.
The FMA publishes authorization notices on its official website at fma-li.li. Firms should monitor that register directly for updates, as additional authorizations under both the full CASP route and Art. 60 are expected to follow as the post-transitional MiCAR period progresses.