Sanctions 2026

LIECHTENSTEIN Law and Practice Contributed by: Lukas-Florian Gilhofer and Mathias Bitschnau, Ospelt & Partner Attorneys at Law Ltd

tions, decided at the UN and EU levels and transposed into national law through autonomous adoption. Individual sanctions include the freezing of funds and economic resources belonging to listed persons and organisations, as well as travel restrictions in the form of bans on entry and transit. Sectoral sanc - tions encompass goods and technology embargoes – including export control measures for dual-use items and military equipment – service prohibitions with respect to financial, transport, IT and advisory servic - es provided to sanctioned countries or persons, and sector-specific measures targeting particular areas of the economy such as energy and defence. These sanctions are based on resolutions of the UN Security Council as well as on measures adopted by the EU, which Liechtenstein implements within the framework of the EEA Agreement and through bilat - eral arrangements with Switzerland. 1.4.3 Domestic and/or Supranational Measures In Liechtenstein, sanctions are imposed at three dif - ferent levels. • UN – as a member of the United Nations since 1990, Liechtenstein is bound by resolutions of the UN Security Council adopted under Chapter VII of the UN Charter. These are transposed into national law by means of government ordinances issued on the basis of the International Sanctions Act (ISG). In certain cases – particularly following the legislative reform introducing Article 14a ISG – the relevant UN sanctions lists are incorporated auto - matically and with immediate legal effect. • EU – although Liechtenstein is not an EU member state, its membership of the European Economic Area (EEA) and its close economic ties with the EU mean that EU restrictive measures are adopted autonomously through decisions of the EEA Joint Committee and corresponding government ordi - nances. In practice, this results in Liechtenstein’s sanctions landscape being almost entirely aligned with that of the EU, encompassing the full range of country-specific regimes – including those target - ing Russia, Belarus and Iran – as well as thematic measures such as those addressing terrorism financing and human rights violations.

• Switzerland – a further layer arises from the cus - toms union with Switzerland. Since Liechtenstein and Switzerland form a single customs territory, Swiss sanctions administered by the State Sec - retariat for Economic Affairs (SECO) are equally applicable in Liechtenstein, adding a third strand of supranational measures that shapes the practical compliance environment. At the purely domestic level, Liechtenstein formally maintains its own national sanctions list, published as annexes to ordinances issued under the ISG. In practice, however, this list is of limited autonomous significance, as it constitutes in substance a verbatim transposition of the EU sanctions list, adopted with - out independent screening or additional designations. The government does retain a limited power under the ISG to designate persons directly in the annex - es to national ordinances – notably in the context of counter-terrorism measures under UN Security Coun - cil Resolution 1373 (2001), where it may act on the basis of decisions by competent domestic or foreign authorities. However, such autonomous national des - ignations remain the exception rather than the rule, and the Liechtenstein list derives its practical content almost exclusively from the EU framework. The overall picture is therefore one of a jurisdiction that operates primarily as an implementing jurisdic - tion: the substantive designation decisions are made at the UN or EU level, while Liechtenstein’s role is to transpose and enforce those measures through its national legal framework, with the ISG and the govern - ment’s ordinance-making power forming the central instruments of implementation. 2. Overview of Regulatory Field 2.1 Primary Regulators The primary regulators for sanctions activity in Liech - tenstein are: • the Financial Market Authority (FMA); • the Office of Foreign Affairs; • the Financial Intelligence Unit (FIU); and • the Government of the Principality of Liechtenstein.

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