International and EU sanctions
Since its accession to the UN in 1990, Liechtenstein has been obliged under international law to 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 relate in particular to the movement of goods, services, payments, capital and persons. They serve to respect and enforce international law, in particular fundamental human rights.
In addition, Liechtenstein participates in individual sanctions of the European Union (EU) within the framework of autonomous enforcement.
The legal basis for the domestic implementation of UN and EU sanctions is the Act on the Enforcement of International Sanctions (ISG). The Swiss legal provisions applicable in Liechtenstein on the basis of the customs treaty with Switzerland must be taken into account in the movement of goods and persons. They are implemented in individual cases by ordinance.
The FIU staff unit acts as an enforcement authority. Depending on the ordinance and the sanction, the government may designate additional or other offices as enforcement authorities in accordance with their area of responsibility.
Counter Terrorist Financing Taskforce - Israel (CTFTI) - FIU Task Force Public Statement
SFIU fact sheet for the application for an exemption permit based on the Ordinance on Measures in Connection with the Situation in Ukraine
FAQ for practical questions on the Ordinance on Measures in Connection with Ukraine (version dated 29.06.2022)
FAQ for practical questions relating to Article 29d of the Ordinance on Measures in Connection with Ukraine (version dated 12.02.2025)
To enter the report "ISG - Information without TRX (temp. for Art. 22a)", you can download the XML file "Download template report" locally. Download the XML file as a file by right-clicking on the link and selecting "Save link as...". Please log in to the goAML Web Portal and select the menu item "New reports - Web report". You can then upload the XML file as described in the video "Report creation instructions" and create the report.
Download report template (xml)
Report creation instructions
EU FAQ for practical questions relating to Article 22a of the Regulation on measures in relation to Ukraine (update 06.03.2025)
Chapter 13 "Reporting on outgoing transfers" of the EU FAQ (p. 110 as of 24.02.2025):
https://finance.ec.europa.eu/publications/consolidated-version_en
The reporting form to be used corresponds to the form used in the EU. It can be downloaded from the aforementioned link in chapter 13 in the answer to question no. 14 (p. 113). Alternatively, the form can also be obtained from the following link:
https://finance.ec.europa.eu/document/download/c36b6910-a3e4-4a5b-a342-3f34aab4568b_en?filename=faqs-sanctions-russia-outgoing-transfer-article-5r-reporting-template_en.xlsx
The report type "ISG - Information without TRX (temp. for Art. 22a)" must be used to record the report to the SFIU. The reporting form linked above must be attached to the notification for this purpose. In the report itself, only the information on the person submitting the report must be provided.
FAQ for practical questions relating to Article 22a of the Ukraine Regulation (version dated 05.05.2025)
Information on sanctions lists
The FIU staff unit informs about adjustments to the applicable sanctions lists via a newsletter. This service ensures that registered users are informed in good time about upcoming changes affecting their own Know-Your-Customer (KYC) efforts.
Registration for the newsletter can be made via the following link: https://newson.llv.li/ under the Financial Intelligence Unit / ISG section.
When searching for listed persons, companies and organizations (UN sanctions), the following URL may be particularly useful: -
Website of the UN: https://www.un.org/sc/suborg/en/sanctions/un-sc-consolidated-list
On the basis of this ISG, Liechtenstein can also implement sanctions that the EU imposes as part of its common foreign and security policy and with which Liechtenstein regularly associates itself as part of the political dialog between the EU and the EEA/EFTA states and on the basis of its foreign policy priorities. However, in contrast to the sanctions of the United Nations Security Council, there is no obligation under international law to implement them. They are implemented on a case-by-case basis by ordinance.
These ordinances are available at the URL www.gesetze.li.
Information on new ordinances is communicated via the newsletter "Neueste Landesgesetzblätter" or at the URL https://www.gesetze.li/chrono/neueste-lgbl.
EU sanctions overview: https://www.sanctionsmap.eu/
Legal basis:
Law on the Enforcement of International Sanctions (ISG)
Law ISG (English version, for information only)
Within the scope of its responsibilities, the FIU staff unit has issued guidelines for the enforcement of international sanctions. The document can be found here:
ISG-Guidance (english version, for information only)
Within the scope of its competence, the government has issued a directive on listing and de-listing procedures for the enforcement of international sanctions. The document can be found here:
Other authorities relevant to this topic:
The national supervisory authorities for the Due Diligence Act (DDA) are responsible for monitoring compliance with the special obligations of persons subject to due diligence arising from the ISG.
Liechtenstein Financial Market Authority
Liechtenstein Chamber of Lawyers
The Government Legal Service is responsible for preparing the draft ordinances and submitting them to the Government for approval.
Legal Service of the Government
The Office of Foreign Affairs advises the Government on the adoption of coercive measures:
Based on the customs treaty between the Swiss Confederation and the Principality of Liechtenstein, the Swiss SECO - State Secretariat for Economic Affairs is also the competent authority for domestic applicants within the scope of the movement of goods and persons:
SECO - State Secretariat for Economic Affairs
Further links: