Liechtenstein vs San Marino
Crypto regulation comparison
Liechtenstein
San Marino
Liechtenstein's Blockchain Act (TVTG) effective since 2020 is among the world's most comprehensive crypto frameworks. The FMA supervises registered TT service providers. Adapted for EU MiCAR in 2025.
San Marino has developed a regulatory framework for blockchain entities. The country has issued licenses for blockchain-based businesses.
Key Points
- Blockchain Act (TVTG) adopted unanimously in 2019, effective Jan 2020
- Token Container Model enables tokenization of any asset or right
- FMA registers and supervises all TT service providers
- EEA MiCAR Implementation Act entered into force Feb 2025
- First country with comprehensive blockchain-specific legislation
Key Points
- Delegated Decree on blockchain technology entities issued
- Licenses issued for blockchain-based businesses
- AIF provides regulatory oversight
- Small jurisdiction working to attract blockchain companies
- Developing comprehensive digital asset regulation