Government decides on further action in relation to entities without legal organs

The measures were developed by the task force set up in mid-2025. They are designed to strengthen legal certainty on the one hand and to continue to make it impossible to circumvent sanctions on the other.

A high degree of compliance with applicable international and European standards is of central importance for the Liechtenstein financial centre. Based on its long-term financial centre strategy, Liechtenstein has been implementing effective measures for years to achieve the objectives of this strategy and thereby ensure unrestricted and equal market access. This also includes a consistent sanctions policy.

In line with this consistent policy and based on Liechtenstein’s close relations with the EU, Liechtenstein generally participates in European Union sanctions on an autonomous basis.  This also applies to EU sanctions in connection with Russia’s war of aggression against Ukraine. Furthermore, additional steps have been taken to ensure that sanctions imposed on Russia by other economic partners are also complied with in Liechtenstein. To this end, specific notices and guidelines have been developed and published by both the Liechtenstein Financial Market Authority (FMA) and various professional associations.

No circumvention of sanctions possible

Liechtenstein’s sanctions policy in the context of the war in Ukraine has led to resignations from the governing bodies of legal entities domiciled in Liechtenstein. This affects legal entities that are subject to the European Union sanctions autonomously implemented in Liechtenstein, have a general connection to Russia, or are affected by the sanctions regimes of other Liechtenstein partners, including the sanctions imposed by the United States of America. In the case of a given connection to US sanctions (in most cases, this refers to designated economic sectors rather than sanctioned individuals), the inevitable consequence of the measures taken in Liechtenstein is that these legal entities can neither be continued nor wound up and must therefore remain without governing bodies.

The legal entities concerned are in liquidation, but the proceedings have been suspended and the assets frozen due to the lack of organs capable of acting. This ensures that the assets in question can no longer be used to support Russia’s war of aggression in Ukraine or to circumvent national or foreign sanctions. In order to analyse the situation and identify possible further action to be taken in relation to legal entities without governing bodies, the government set up a task force in mid-2025.

The steering group categorised the relevant cases, particularly those involving legal entities without organs, and analysed and proposed options for further action.

Commercial Register Ordinance has been amended

For the authorities, entities without governing bodies are entities for which the official procedure for dissolution and liquidation has had to be interrupted because no one could be appointed as liquidator. This currently affects around 150 legal entities. These legal entities are without governing bodies because the appointment of a governing body or liquidator is generally not possible for the duration of national and foreign sanctions. These are primarily cases in which the Administrative Appeals Commission (VBK) has ruled that the appointment of the last body in accordance with Art. 180a of the Law on Persons and Companies is unreasonable due to an existing risk of sanctions. These cases are the result of consistent adherence to the sanctions policy; a change in this situation will generally only be possible if the underlying sanctions are lifted.

In this context, the amendment to the Commercial Register Ordinance adopted by the government on 3 February 2026 now expressly provides for the possibility of official proceedings being suspended or remaining suspended if there are important reasons preventing the appointment of a liquidator. This allows the Office of Justice  to suspend the official procedure for appointing a liquidator or to maintain the suspension if, for important reasons, a liquidator cannot be appointed.

Legal entities without assets can be deleted from the commercial register after a bankruptcy petition has been dismissed due to lack of assets.

A curator can be appointed

In cases where urgent administrative measures need to be taken, Liechtenstein law provides for the possibility of appointing a curator. Once appointed in relation to a specific company, the curator may take measures to carry out urgently needed administrative actions in the case in question.

In cases that are Russia-related but not related to national or international sanctions, a body shall be appointed in accordance with article 180a of the Persons and Companies Act or a liquidator shall be appointed. These legal entities may be continued or liquidated.

This approach ensures that the rule of law is upheld while preventing sanctions from being circumvented. The steering group will remain in place until further notice so that it can respond quickly and flexibly to new conditions in the dynamic sanctions environment.