International sanctions

Since its accession to the UN in 1990, Liechtenstein has been obliged under international law to domestically implement sanctions adopted by the UN Security Council in the form of resolutions. Such sanctions are measures of a non-military nature against individual States, organizations, or persons and affect in particular the movement of goods, services, payments, capital, and persons. They serve to respect and enforce international law, namely fundamental human rights. Liechtenstein is committed to the effective implementation of UN sanctions, but also to improved transparency as well as compliance with rule of law principles by the UN Security Council when issuing sanctions (Ombudsperson, delisting procedure).

In addition, Liechtenstein autonomously adopts sanctions of the European Union (EU) and associates itself in these cases with the corresponding foreign policy statements of the EU.

Switzerland's coercive measures are taken into account when Liechtenstein issues sanctions due to the common customs territory on the basis of the customs treaty between Liechtenstein and Switzerland.

Legal basis and automatic adoption of UN sanctions lists

The legal basis for the domestic implementation of international sanctions is the Law on the Enforcement of International Sanctions (ISG). The ISG is designed as a framework law that empowers the government to enforce internationally based sanctions by issuing coercive measures at the national level. It is implemented on a case-by-case basis through an ordinance. In the case of UN Security Council sanctions, since 2017 there has been an automatic adoption of the sanctions lists and their amendments, based on Art. 14a ISG and the provisions in the relevant ordinances. Amendments to the UN sanctions lists are thus immediately legally valid in Liechtenstein. The automatic adoption allows for implementation without delay and thus complies with the internationally required standards of the Financial Action Task Force (FATF) to combat money laundering and the financing of terrorism and proliferation.

A complete list of all Liechtenstein ordinances implementing international sanctions can be found in consolidated form here. The UN sanctions lists that are directly legally valid in Liechtenstein are publicly available via the UN homepage. The Financial Intelligence Unit (FIU) offers a newsletter service through which due diligence entities are informed of changes to the sanctions lists (Website FIU).

Competent Authorities

The Office for Foreign Affairs and the Government Legal Services are in charge of implementing international sanctions into national law. The Financial Intelligence Unit (FIU) has the function of an enforcement authority for financial sanctions. It also examines requests for exemptions. In addition to the FIU, depending on the ordinance and the sanctions regime, the government may designate other agencies as enforcement authorities in accordance with their areas of responsibility. The Financial Market Authority Liechtenstein (FMA) and the Liechtenstein Bar Association are designated as competent supervisory authorities.

Information on delisting procedures in connection with UN sanctions:

Office of the Ombudsperso (in case of ISIL (Da'esh) and Al-Qaida sanctions)

Focal Point for De-listing (in case of all other UN sanctions regimes)

For more information on national de-listing procedures, see the ISG Guidance and Instruction on Procedures for Requests for Inclusion on or Removal from a Sanctions List, available on the FIU Homepage.