As per Regulation (EU) No 575/2013 (CRR), Article 4(1)(26) financial institution means an undertaking other than an institution and other than a pure industrial holding company, the principal activity of which is to acquire holdings or to pursue one or more of the activities listed in points 2 to 12 and point 15 of Annex I to Directive 2013/36/EU, including an investment firm, a financial holding company, a mixed financial holding company, an investment holding company, a payment institution within the meaning of Directive (EU) 2015/2366 of the European Parliament and of the Council ( 11 ), and an asset management company, but excluding insurance holding companies and mixed‐activity insurance holding companies as defined in points (f) and (g) of Article 212(1) of Directive 2009/138/EC.

In Liechtenstein, trust companies carry out the following activities (according to Art. 2 Trustee Act):

a) Establishment of legal entities, companies and trusteeships for third parties, in the licence holder’s own name and for the account of third parties and related contact and correspondence with courts and administrative authorities; 

b) Acceptance of board mandates in accordance with Art. 180a of the Liechtenstein Law on Persons and Companies and acceptance of trusteeships; 

c) Financial and business consultancy; 

d) Tax consultancy; 

e) Bookkeeping and audit review, provided this activity is not reserved for auditors and auditing companies.

There are credit institutions in Liechtenstein that hold such trust companies as subsidiaries. Do these companies fall under the definition of “financial institution” and are therefore part of the scope of prudential consolidation?