Corporate law · In-depth analysis

Liechtenstein: trust law reform and “zombie trusts” in sanctions practice

Since July 1, 2026, updated trust law has been in effect in Liechtenstein: governance, information rights and judicial supervision have been strengthened, documents and registration information have been clarified. In parallel, the practice encountered structures that lost fiduciaries or bodies due to sanctions risks. They are sometimes informally called "zombie trusts", although there is no such term in law.

Key points
  • The PGR reform came into force on July 1, 2026 and aims to continuously monitor trustee activities.
  • Trust documents, rights to information, judicial mechanisms and oversight of charitable trusts have been clarified.
  • A “zombie trust” is not a legal category; it would be more accurate to talk about an orphaned structure or a structure without an active fiduciary/body.
  • Sanction restrictions may block the appointment of a new body or liquidator; assets remain frozen, and urgent actions are possible through a curator in appropriate cases.

01

How does a Liechtenstein trust work?

Liechtenstein Treuhänderschaft arises when a settlor transfers property or a right to a trustee who manages it in his own name as a separate legal owner for the benefit of beneficiaries or for a specified purpose. The trust itself does not have a separate legal personality.

A trust with a term of more than twelve months must be registered with the Commercial Register or its articles of incorporation deposited with the Office of Justice within the prescribed period. Information about beneficial owners also falls under the special VwbP register.

02

What has changed since July 1, 2026

Law LGBl. 2026 Nr. 12 changed the PGR section about trusts. The reform was prepared as “Optimierung Trustrecht” and is focused on effective and continuous control of trust property management, eliminating governance gaps and strengthening the international recognition of the structure.

Documents

The law distinguishes in more detail between trust deed and additional trust documents and establishes their mandatory content.

Information

The persons having rights to information and control and the methods for their implementation are specified.

Judicial supervision

Procedural mechanisms for responding to violations of trustee obligations are being strengthened.

Transparency

The list of information declared when registering a trust relationship is being adjusted.

03

Charitable trusts and new supervision

Charitable trusts are now subject to oversight by a body renamed the Foundation and Trust Supervisory Authority. The model relies on an annual review of the management and use of trust assets by an independent court-appointed auditor.

The supervisory authority receives the status of information-entitled person and procedural rights before Landgericht. Tax applications and materials related to the charitable exemption are filed directly with the Tax Administration.

04

What is called a “zombie trust”

This is a colloquial designation for a structure that legally continues to exist and owns assets, but in fact cannot function normally: the trustee or other fiduciary has left, the new professional is unable or unwilling to accept the appointment, orders are blocked, and the liquidation is not completed.

Official documents use more precise expressions: entities without governing bodies and orphaned structures. The term can cover not only trusts, but also foundations, establishments and other legal entities. Therefore, in each case, the legal form and specifically the missing body are first determined.

Terminology

A “zombie trust” does not mean that the structure is illegal or that its assets are not owned by anyone. This is a description of a governance deadlock, not a stand-alone PGR status.

05

How sanctions create a governance deadlock

Liechtenstein applies its own sanctions regulations and autonomously replicates a number of EU measures. Certain relationships are prohibited from creating trusts, providing address and administrative services, or serving as a trustee or similar role; the scope of the ban and exceptions are checked according to the current version of the resolution.

In 2025, resignations of fiduciaries and board directors from structures with the corresponding risk nexus became more frequent. The reason may be not only the direct inclusion of a person on the sanctions list, but also the risk of secondary consequences, restrictions on professional services, banking compliance and the inability to accept a role without violating the applicable regime.

06

What is provided for structures without organs

The government reported approximately 150 legal entities without operating bodies for which the appointment of an authority or liquidator was not possible for the duration of the restrictions. In February 2026, the Commercial Register Ordinance was amended so that official proceedings can be suspended if important reasons prevent the appointment of a liquidator.

The assets of such structures remain frozen. If urgent administrative action is necessary, the law allows for the appointment of a curator for a specific company. This is not a universal way to resume activity or circumvent restrictions: the scope of authority is determined by the purpose and the applicable decision.

07

Beneficial ownership and AML

Register of Beneficial Owners covers companies, foundations and trusts. Structure managers are required to keep the information up to date in accordance with the VwbPG. A foreign trust may also fall within the scope of registration if it is administered in Liechtenstein or forms a statutory connection with the jurisdiction.

A change of trustee, protector, beneficiary or controlling person must be considered simultaneously under trust deed, PGR, professional regulation, AML and sanction rules. A formal replacement of a person without actual independence and verification of the source of wealth creates a separate risk.

08

Checking the existing structure

  • 01

    Set the form of the structure and the current edition of trust documents.

  • 02

    Check the powers, resignation and possibility of replacing the trustee, protector and other bodies.

  • 03

    Compare settlor, successor, controlling persons and assets with applicable sanctions regimes.

  • 04

    Check VwbP, Commercial Register and other registration obligations.

  • 05

    Determine whether payments, management, change of bank, and professional fees are permitted.

  • 06

    Assess judicial appointment, curator, stay of proceedings or liquidation.

  • 07

    Record decisions and maintain independent sanctions/AML analysis.

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Sources

Primary materials behind this article

We rely on official guidance and legal materials. Their current version and the client’s circumstances must be checked before any transaction.

02

Government Report and Motion 17/2025

Reform goals: governance, information rights, judicial control and prevention of control gaps.

Open official source
03

Government: entities without legal organs

Official description of approximately 150 structures, suspension of procedures and curator capabilities.

Open official source
04

Liechtenstein sanctions ordinance

Consolidated chronology of the resolution on measures in connection with the situation in Ukraine.

Open official source
05

Office of Justice: Register of Beneficial Owners

Purpose of VwbP and coverage of companies, foundations and trusts.

Open official source
06

IMF Article IV 2026: Liechtenstein

Independent assessment of resignations, orphaned structures and measures to strengthen oversight.

Open official source
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