Sanctions 2026

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

Liechtenstein in the International Sanctions Framework The ongoing war of aggression against Ukraine has established Liechtenstein as a small but determined actor within the international sanctions architecture. As a member of the European Economic Area (EEA) without full EU membership, the Principality pursues a consistent policy of autonomously adopting succes - sive EU sanctions packages – a course that increas - ingly gives rise to domestic political and economic challenges. At the same time, Liechtenstein’s finan - cial centre faces a structural challenge of a different nature: the extraterritorial reach of the United States sanctions regime administered by the Office of For - eign Assets Control (OFAC). Two developments there - fore define Liechtenstein’s sanctions law landscape in 2026: the seamless transposition of escalating EU sanctions packages, now reaching the 21st pack - age against Russia, and a serious crisis of so-called “orphaned legal entities” within the financial centre, the resolution of which remains one of the most press - ing regulatory and legal challenges the Principality has faced in recent years. Trend one: autonomous adoption of EU sanctions packages Liechtenstein is not an EU member state but is closely integrated into the European legal area through the EEA and its customs union with Switzerland. In the field of sanctions, there is no direct obligation to implement decisions adopted by the EU under the Common Foreign and Security Policy (CFSP). Nev - ertheless, since the outbreak of the Ukraine war in 2022, the Liechtenstein government has committed to a policy of autonomous adoption: EU sanctions regulations are as a rule transposed rapidly and com - prehensively into the national Ordinance on Measures in connection with the Situation in Ukraine, covering both designated persons lists and sectoral measures in the fields of trade, energy and finance. This practice distinguishes Liechtenstein from other third states that either adopt no sanctions or do so only selectively. It places the Principality in a posi - tion of de facto political solidarity with the EU that goes well beyond its formal legal status and reflects a deliberate strategic choice to align Liechtenstein’s international posture with that of its closest partners.

The pace and comprehensiveness of adoption have intensified markedly over recent months, signalling not merely a reactive compliance exercise but an increas - ingly proactive commitment to the broader European sanctions effort. Timeline of recent packages The most significant transposition steps taken since mid-2025 are as follows. • May 2025: Transposition of the remaining elements of the 16th EU sanctions package (adopted by the EU on 24 February 2025), targeting economic sectors generating significant foreign revenues for Russia, including measures against vessels of the Russian shadow fleet and transaction prohibitions vis-à-vis banks using Russian financial messaging services. • March 2026: Adoption of an ordinance amendment implementing the 19th sanctions package (adopted by the EU on 23 October 2025), including a general prohibition on the purchase and import of Russian liquefied natural gas (LNG), alongside the second and final part of the EU’s October 2025 Belarus sanctions package aimed at preventing the circum - vention of Russia-related measures. • 28 April 2026: Adoption of the first part of the 20th sanctions package – only five days after the Coun - cil of the EU adopted it on 23 April 2026 – impos - ing financial and travel sanctions on 120 individuals and entities supporting Russia’s military-indus - trial complex and enabling its continued military aggression against Ukraine. The speed with which the 20th and 21st package were transposed – just five days in each case, from EU adoption to national ordinance – is particularly note - worthy. It reflects both the political will of the Liechten - stein government and the administrative capacity that has been built up over successive rounds of adop - tion. For financial intermediaries and legal advisers operating in the Principality, this pace underscores the importance of maintaining real-time monitoring of EU sanctions developments, as the window between EU adoption and domestic applicability has become extremely narrow.

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