Euroclear frozen assets: how to unfreeze them step by step

Since autumn 2025 nearly every application has ended in refusal, but on 11 September 2026 Belgium's top administrative court overturned one of those refusals. A step-by-step guide: where the securities actually sit, how to choose between a Belgian or Luxembourg license, a Russian court and a sale, what to file, what it costs and how to avoid scammers.

On 11 September 2026, Belgium's Council of State (Raad van State), the country's highest administrative court, overturned a refusal by the Belgian Treasury to release assets frozen at Euroclear, the international central securities depository based in Brussels. The applicant was BCS Bank: it filed in January 2023 and was turned down on 15 July 2024. The court never reached the merits. It ruled that the official who signed the refusal lacked proper authority and sent the application back for a fresh decision.

For holders of frozen securities, this is a precedent that can be cited when appealing refusals. In autumn 2025 up to 99% of Treasury decisions on private investors were refusals. The stakes are huge: the Bank of Russia estimates that Russian investors have about $67 billion stuck at Euroclear and Luxembourg-based Clearstream, about 20% of it belonging to private individuals. In October 2025, central bank governor Elvira Nabiullina told the State Duma that roughly half had been recovered one way or another. The half that remains is the hard cases.

What follows is a step-by-step guide: how to find out where the securities actually sit, which route to choose, what to file and what happens after a license. The timeline since 2022 and a market overview are in our separate article on unblocking frozen brokerage assets.

What changed for frozen assets in 2026

The big story of the year is not new licenses but a dispute over who is allowed to grant them at all. Because of it, the Belgian Treasury froze decisions for about seven months and then went back to refusing.

High politics runs in parallel. On 12 December 2025 the EU froze Bank of Russia assets of about $240 billion indefinitely. On 15 May 2026 the Moscow Arbitration Court awarded the Russian central bank about $220 billion against Euroclear; the appeal court upheld the ruling in July, and on 24 September Euroclear filed cassation appeals. These cases affect a private portfolio only indirectly, but they make the climate around every application harsher.

If the securities are blocked not at the Belgian depository but at a broker, the procedure is different: unblocking frozen brokerage assets.

Step 1. Where the securities actually sit

A foreign share in a Russian brokerage statement is almost never held by the broker itself. The typical chain runs from the broker to its depository, then to the National Settlement Depository (NSD), then to Euroclear Bank in Brussels or Clearstream Banking in Luxembourg. For US securities, US market infrastructure sits behind Euroclear as well. On 3 June 2022 the NSD was added to the EU sanctions list (Annex I to Regulation 269/2014), and everything held in its accounts froze with it.

The European Commission spells out the logic in its guidance on central securities depositories: whatever the NSD holds, even temporarily and on behalf of clients, counts as frozen. The securities still belong to the investor, but any operation with them needs permission from the regulator of the country where the European depository sits.

Securities held through SPB Bank are a separate story. The block there is American: in November 2023 OFAC, the US Treasury's Office of Foreign Assets Control, added SPB Exchange to its sanctions list. European licenses do not solve that problem.

So the work starts with a request to the broker. What is needed: a custody account statement showing where each security is held and its ISIN (International Securities Identification Number), brokerage reports with purchase dates, and an answer to one question - did the broker or the NSD file a collective application with the Belgian Treasury before 7 January 2023? That deadline is written into the EU regulation itself, and the Treasury still looks at it.

Step 2. Which unblocking route to choose

There are four routes, and they do not mix well. A license gives a chance to get the securities themselves back, but it is slow and expensive. A Russian court gives roubles on paper that are hard to collect. A sale brings cash quickly, but at a discount of up to 70%. Here is how they compare on public data:

Belgian license: the main route for Euroclear

The Belgian Treasury grants individual authorisations under Article 6b(5) of EU Regulation 269/2014. That provision allows NSD assets to be released where needed to wind down operations entered into before 3 June 2022. The regulation sets a deadline of 7 January 2023, which is why it matters whether the broker filed a collective application by that date.

Since autumn 2025 the Treasury has demanded proof of a complete break with the NSD and looks at the purpose of the operation: withdrawal or sale, not continued investing through sanctioned infrastructure. There is good news too. Since autumn 2025 Euroclear has executed Belgian licenses without a separate OFAC authorisation where no US parties are involved in the chain or the transaction. Before that, the need for two licenses killed most cases.

Luxembourg license: cash is easier than securities

On 16 December 2022 Luxembourg issued a general authorisation, and that effectively closed the Article 6b(5) route for individual applications. Applications are now built on Article 6 of the regulation: release of assets to perform obligations that arose before the sanctions. Unlike Belgium, no guarantor is required.

Since 2025 Luxembourg's finance ministry has approved payouts of coupons, dividends and redemptions more often. The securities themselves are harder: there is still no reliable data on licenses to move them out.

Russian court: a win that is hard to collect

Russian courts do award damages against Euroclear. In early 2026 the Arbitration Court of the Ural District upheld the recovery of unpaid income from Euroclear and Clearstream in favour of a Russian investor (case A60-22233/2024). On 6 April 2026 the Moscow Arbitration Court awarded Alfa-Capital about $180 million in unpaid income against Euroclear. Yet in January the same court had rejected its claim for the value of the securities themselves, about $3.8 billion: in the court's view, a freeze does not mean loss of ownership.

There are three problems. First, Decree No. 8 of 3 January 2024 bars enforcement against type C accounts (special accounts at Russian banks and depositories that hold money and securities of foreigners from unfriendly countries) under judgments issued after that date, and that is exactly where Euroclear's assets in Russia sit. Second, on 30 April 2026 the Moscow Arbitration Court turned down a private investor because he had not appealed the Treasury's refusal to Belgium's Council of State; the claim was ruled premature. Third, Article 11a of Regulation 833/2014 lets an EU company recover damages and legal costs from a Russian claimant, and the 21st package widened those rules. A court case and a license therefore pull in opposite directions, and the line should be chosen before the first document is filed.

Sale and swap: fast, but expensive

An over-the-counter sale is the only fast exit, and the speed is paid for with a discount. The swap under Decree No. 844 returned about $130 million to investors in 2024 against tens of billions in bids, and the first round was capped at about $1,200 per investor. The European Commission has explicitly barred EU persons from taking part in such swaps. Joining dubious schemes can also hurt a later license application, because the regulator will question the applicant's good faith.

Step 3. What documents a license needs and where to file

The Belgian Treasury decides on paper, with no interviews. Anything missing from the file does not exist for it. So most of the work happens before filing: proving the custody chain, the purchase date and the owner's clean record, and lining up a broker willing to take the assets.

The weakest point is usually not the passport but the source of funds: an EU broker will check it harder than a Russian bank. How to build that file is covered in our article on proof of source of funds. Russian-language documents need translation, which is a job of its own and easiest to order together with apostille and certification.

Where to file:

• Belgium. An application addressed to the finance minister via the General Administration of the Treasury, Avenue des Arts 30, 1040 Brussels. The Treasury's official address for financial sanctions questions is [email protected]. Once filed, the application gets a number, and the clock starts from there.
• Luxembourg. Ministry of Finance, Directorate of Multilateral Affairs, Development and Compliance, 3 rue de la Congrégation, L-1352 Luxembourg; email [email protected]. The finance minister has the power to grant exemptions from sanctions.
• United States. OFAC's online license application portal. Registration is optional; status is checked by Case ID.

There is no public information on government fees for such applications in Belgium or Luxembourg. The main costs are legal support, the guarantor, translations and the receiving broker. We quote the cost of our support after reviewing your documents.

Step 4. What happens after the license is granted

A license is a permission, not a transfer. The second half of the journey starts after it, and cases get stuck there too.

1. Euroclear compliance. The depository runs its own review. If there is no US infrastructure and no US party in the chain, it has not required an OFAC license since autumn 2025. But a transfer can stall without a formal refusal. In such cases, in practice, pre-litigation claims against Euroclear, combined with complaints to the ombudsman and the financial regulator, can help.
2. The receiving broker. It may ask for more than Euroclear does, including an OFAC license. If the broker is in Cyprus, since spring 2025 a separate license from the Cypriot finance ministry's Sanctions Implementation Unit is also required: the first ones were issued in July 2025, with reviews taking about three months.
3. Crediting and sale. The securities arrive together with years of accumulated coupons and dividends, if their payout was authorised too. Then a limit kicks in: Article 5b of Regulation 833/2014 bars EU banks from accepting deposits above EUR 100,000, about $120,000, per bank from Russian nationals and residents. The limit does not apply to citizens of the EU, the European Economic Area and Switzerland, or to holders of residence permits there. So selling a large portfolio without European status quickly hits the ceiling.
4. Taxes. Selling unblocked securities and receiving coupons are taxable events. Russian tax residents must notify the Federal Tax Service of a foreign account and report the income; non-residents follow different rules. Residency is explained in our article on the 183-day rule, and country rates are in our tax guide.

If a refusal arrives, the clock is measured in weeks. A Treasury decision can be challenged before Belgium's Council of State within 60 calendar days of notification, and the deadline cannot be extended. After the BCS Bank ruling, the first thing to check is who signed the refusal and when: decisions signed under the delegation scheme the court found unlawful are now vulnerable. The refusal is not cancelled automatically and the assets are not released: the application is simply reviewed again, and the Treasury can refuse once more if it follows the procedure.

What we do: from the broker statement to the credited account

Most refusals are born not in Brussels but at the preparation stage: the wrong legal provision in the application, no guarantee letter, no proof of the purchase date. That is why we run the whole case rather than sell a template application.

1. Custody chain review. We request statements from the broker, trace each security to Euroclear, Clearstream or SPB Bank, and find out whether a collective application was filed before 7 January 2023.
2. Choice of route. We run the numbers on a license, a court case and a sale for the actual portfolio. If the portfolio is too small for a license, we say so before any money is spent.
3. Preparing the file. Documents, translations, the source of funds file and an application citing the right provision of the regulation.
4. Dealing with the broker and depository. The Russian broker, its depository, the receiving broker in the EU and its compliance team: requests, letters, agreeing the guarantee letter.
5. Representation in Belgium and Luxembourg. Filing, contact with the Treasury and the ministry, and appeals to the Council of State are handled by Murblz specialists together with locally licensed partners.
6. Support until the assets are credited. Execution of the license at Euroclear or Clearstream, the Cypriot license if the broker is in Cyprus, and the tax consequences of a sale.

The receiving account is best opened before filing: without it, the Treasury cannot see where the assets will go. Where and on what terms an account can realistically be opened is covered in our guide to opening a bank account abroad.

How long unblocking assets at Euroclear takes

The most common mistake is to count from filing to decision. In reality the decision is the halfway point. A real case: application filed in 2023, authorisation granted in 2024, and securities worth USD 2.1 million reached a European broker only in early 2026. Almost three years.

The whole journey usually takes 6-8 months in a favourable scenario, 10-14 on average, and 24-30 months with a refusal and appeal. Only one's own part can be sped up: the file, the guarantee and the account. Nobody speeds up the queue in Brussels.

How to spot scammers in asset unblocking

A frozen portfolio is perfect bait: its owner has waited years for good news and is ready to pay for hope. As early as 10 January 2024 the Bank of Russia warned about schemes asking investors to transfer a sum equal to the value of their frozen assets with a promise to return double. In June 2026 Russia's FSB said it had uncovered a scheme in which, according to investigators, a Cypriot broker and a Russian investment company used forged documents when swapping frozen depositary receipts.

Signs that the conversation should end:

• A guaranteed outcome or deadline. The decision is made by the finance minister of Belgium or Luxembourg, not by an intermediary.
• A promised success rate above 80-90% against a backdrop of near-total Treasury refusals in 2025-2026.
• A request to pay an unblocking fee or a deposit to a card or a crypto wallet.
• An offer to move the securities to someone else's account to speed things up.
• A general power of attorney over the assets instead of a narrow one for filing documents.
• Friends inside Euroclear. The depository only executes regulators' decisions and decides nothing itself.

Checking takes an hour. Belgian lawyers are listed by the Ordre des barreaux francophones et germanophone and the Orde van Vlaamse balies, Luxembourg lawyers by the Luxembourg Bar (Barreau de Luxembourg). A broker is checked in its home regulator's register, Russian companies on the Bank of Russia website. Murblz specialists vet their partners against the same registers; more on our legal support page.

If frozen securities are part of a bigger move, they are best handled together with residency and taxes rather than separately: EU status affects both the odds of a license and the bank limits. Status options are collected in our sections on residence permits and second citizenship. A good first step is a short consultation on the custody chain.

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