LIECHTENSTEIN Law and Practice Contributed by: Lukas-Florian Gilhofer and Mathias Bitschnau, Ospelt & Partner Attorneys at Law Ltd
1. Trends and Overview 1.1 Sanctions Market
has also transposed into national law through its autonomous adoption process, now allow for restric - tive measures against: • persons who own, control, manage or operate ves - sels transporting crude oil or petroleum products originating in or exported from Russia (since 24 February 2025) (Article 3 (k) of Council Regulation (EU) No 269/2014); • persons involved in, supporting or benefitting from Russia’s military-industrial complex (since 24 Feb - ruary 2025) (Article 3 (l) of Council Regulation (EU) No 269/2014); and • persons who have facilitated transfers of owner - ship, control or economic benefits for sanctioned businesses, especially those linked to individu - als designated under criterion (g) (Article 3 (m) of Council Regulation (EU) No 269/2014, since 13 May 2025). Regarding ancillary sanctions obligations, reporting requirements for financial intermediaries and fiduci - aries have become stricter. In addition, the phenom - enon of so-called “orphaned legal entities” – triggered by the extraterritorial effect of US OFAC sanctions, which has caused numerous Liechtenstein fiduciaries to resign from mandates with Russian connections – has posed structural challenges to the Liechtenstein financial centre that remain unresolved to this day. According to the Liechtenstein government, several hundred foundations and establishments are currently blocked without functioning governing bodies; they can neither be continued nor wound up. The govern - ment is currently examining various legislative and supervisory measures to address this situation. 1.2 Key Trends Over the past 12 months, Liechtenstein’s sanctions landscape has been shaped by a notable expansion and intensification of implementation and compliance activity. The key developments in this period include: • intensified adoption of EU sanctions packages against Russia and Belarus, which Liechtenstein transposes autonomously by virtue of its close economic and legal ties to the EU and the EEA;
As a member of the European Economic Area (EEA), Liechtenstein autonomously transposes the sanctions imposed by the Council of the EU into its national legal order. The sanctions have continued to expand over the last 12 months due to the numerous new EU sanctions packages in the context of the war in Ukraine (the 16th, 17th, 18th, 19th, 20th and 21st sanctions packages). Energy-related sanctions have been expanded, particularly targeting liquefied natural gas (LNG), and hundreds of new Russian and Bela - rusian individuals and entities have been listed under amended or newly introduced criteria. In the field of sanctions, Liechtenstein has experi - enced a marked intensification of regulatory activity over the past 12 months. The continuous expansion of Russia-related sanctions in response to the ongo - ing war in Ukraine has led to increased compliance demands on financial intermediaries, fiduciaries and legal advisers. The Liechtenstein government and the Financial Market Authority (FMA) have stepped up their supervisory activities, in particular with regard to the identification of sanctioned persons and the reporting of frozen assets. Compared to the previous year, the number of enquiries received by the FMA as well as the number of frozen accounts and assets has increased significantly. It should be noted, how - ever, that the majority of cases in Liechtenstein do not involve the direct freezing of bank accounts held by listed individuals, but rather affect legal entities and structures – such as foundations, establishments and trusts – in which a sanctioned person holds a benefi - cial interest or exercises control. In such constella - tions, the assets are frozen indirectly, as the relevant legal vehicle becomes ownerless or unmanageable in practice, rendering any disposition over the underlying assets legally impermissible. At the same time, the growing complexity of the sanction’s regimes — in particular through the broadening of anti-circumven - tion provisions and the introduction of new sectoral sanctions – has substantially increased the demand for professional advice in practice. In particular, recent listing criteria introduced under the Russian sanctions regime, which Liechtenstein
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