Liechtenstein¶
The Liechtenstein cases show foreign sanctions reaching a small financial centre through supervision rather than law. The regulator holds that such sanctions do not apply in the principality and advises that relationships touched by them be ended at once, and the banks follow the second message. Compliance becomes a matter of managing risk, and whose list it is, and with what legitimacy, does not enter the calculation. The state is left to administer the consequences.
The clerk’s briefs¶
From the clerks, for the Patrician’s eyes
Read these. Owners, employees and creditors of companies left without anyone to run them depend on curators for as long as the sanctions last. Customers whose banks end a relationship on this advice have no Liechtenstein law to appeal to, and the banks need not explain. A list published by any foreign state could be applied by the same route, whoever it targets. Tying the advice to sanctions the principality has adopted itself would close the route; until then the counter decides.
February 2026: Companies nobody may run¶
The government announced measures for around 150 legal entities left without governing bodies, because appointing a liquidator “is generally not possible for the duration of national and foreign sanctions”; the cases, it said, “are the result of consistent adherence to the sanctions policy”. The Commercial Register Ordinance now allows proceedings to be suspended and curators appointed for urgent measures. The clerks note that foreign sanctions, which do not apply directly, have left companies in a legal limbo the state must now administer.
September 2024: The regulator’s advice¶
The Financial Market Authority’s notice on foreign sanctions law states that “Auslandische Sanktionen sind in Liechtenstein nicht direkt anwendbar”, foreign sanctions are not directly applicable, but that ignoring them carries reputational, operational and legal risks. For business relationships with links to OFAC sanctions, it sees “die unverzugliche Beendigung solcher Geschaftsbeziehungen als das einzig taugliche Mittel”, immediate termination as the only suitable means of limiting the risk. The clerks note that the regulator has told the banks to purge in advance what no Liechtenstein law requires them to.