Euroclear and Clearstream are the two settlement houses through which most of the world's cross-border bonds and shares are held and moved. Since 2022 they have also hosted the largest asset freeze in financial history. Two separate stories run through the same plumbing: roughly €193 billion of Russian central-bank reserves immobilised at Euroclear, and several trillion roubles of private investors' securities trapped after the EU sanctioned Russia's National Settlement Depository (NSD). They run on different rules and have very different exits.
What Euroclear and Clearstream are
Euroclear opened in Brussels in 1968 to settle the young Eurobond market, and Euroclear Bank is now one of the two International Central Securities Depositories (ICSDs). The wider group also runs the national depositories for Belgium, France, the Netherlands, Finland, Ireland, Sweden and the UK (CREST). Assets under custody passed €42 trillion in the first nine months of 2025.
Clearstream is the other ICSD — based in Luxembourg, owned by Deutsche Börse, and formed in 2000 from the merger of Cedel (founded 1970) with Deutsche Börse Clearing. It holds around €21 trillion in custody. A standing link between the two houses, the Bridge, lets a bond bought through one settle against a seller in the other, which is why together they define the international securities market.
Holdings here are book entries rather than certificates in a vault, and they are tiered: an investor's broker holds through a local depository, which held through NSD, which in turn held through Euroclear or Clearstream. Freeze one tier and everything above it stops moving — which is precisely what happened to Russian holders.
Why the assets are frozen
EU — Regulation No. 269 (17.03.2014):
Asset-freeze measures against listed persons and entities. NSD's own holdings were frozen and dealing with sanctioned parties prohibited — the step that cut the chain between Russian custody and the ICSDs.
EU — Regulation No. 833 (31.07.2014):
Sectoral measures, including the ban on accepting deposits above €100,000 from Russian persons. Euroclear has read the restrictions broadly, holding payments and transfers even where NSD sits outside the custody chain. The decisive moment for securities was 3 June 2022, when the EU listed NSD itself.
US and UK:
Euroclear also applies OFAC and HM Treasury measures. Where a transaction touches the US dollar or a US person, a separate American license is usually needed on top of the European one.
The immobilised sovereign assets
The headline numbers belong to a different freeze. Around €193 billion of Russian central-bank reserves are immobilised at Euroclear, out of roughly €210 billion across the EU. These are frozen, not confiscated: so far the EU has held a hard line between blocking the assets and seizing the principal.
What the EU has tapped is the income. Immobilised cash throws off interest as bonds mature and are reinvested — about €2.7 billion in the first half of 2025 alone — and since a February 2024 decision the net 'windfall' has been routed to Ukraine. After Belgian tax and fees, roughly €1.6 billion of that half-year was paid over.
Those revenues also service the G7's Extraordinary Revenue Acceleration (ERA) loan — about $50 billion pledged in June 2024 and repaid from the profits rather than the principal. The EU has delivered its €18.1 billion share, and of the $52.4 billion Ukraine raised externally in 2025, more than 70% came through this channel.
The principal itself is the harder question. A proposed 'reparations loan' would have lent some €140 billion of Euroclear's cash balances to Ukraine, repayable only once Russia pays reparations. Belgium, which carries the legal exposure if Russia ever reclaims the assets, refused without binding risk-sharing. In December 2025 the EU instead made the immobilisation indefinite and agreed a €90 billion loan funded by its own borrowing, while reserving the right to reach for the assets later — a reservation that remains a stated option rather than a settled decision.
Who is affected on the private side
The private side of the freeze is far larger in headcount than in value. By Bank of Russia estimates, about ₽5.7 trillion — over €58 billion — of Russian-held securities sit blocked at Euroclear and Clearstream, and roughly a fifth of that belongs to some five million retail investors. Most held their positions through brokers such as:
- Alfa-Bank
- Bank Dom.RF
- Rosbank
- Citibank
- SPb Exchange
- Tinkoff
How a private holder gets unblocked
The only route that has worked with any regularity is an individual license — a derogation — from the competent national regulator. An applicant is generally expected to:
- have a bank account in the EU or Switzerland
- provide documentation on source of funds and asset ownership structure
- engage a European guarantor
An EU residence permit or passport does not substitute for the license, but it makes the surrounding infrastructure workable: a European bank account, a tax number, an address and a payment route the regulator can follow. What decides the application is the ownership chain and the identity of the recipient, not the residence status itself.
The practical first move is to gain a foothold inside the EU. Spain's Digital Nomad permit is a common fast-track, paired with an account at a bank that already has a working practice with Euroclear and Clearstream releases — CaixaBank among them.
The permit itself runs about three months, and the two tracks can overlap: the license application does not have to wait for the card.
Competence follows the location of the assets, and a filing is built for one specific legal basis:
- Belgian Treasury (for Euroclear)
- Luxembourg Ministry of Finance (for Clearstream)
- OFAC (if US dollar involved in structure or sanctions nexus exists)
Review runs 6–16 months.
A European guarantor — a lawyer or a regulated financial intermediary — is normally part of the filing, and the role is not nominal: the guarantor stands behind the due diligence on the portfolio, the payment instructions, the identity of the recipient and the reporting that follows.
Issue of the license opens a separate execution phase of roughly one to two months, in which broker, bank, depositary and regulator all have to act on the same reading of its conditions: transfer instructions for the securities or the cash, the reporting the license imposes, and control over the recipient and the payment route.
Scale matters, though. The Belgian Treasury has issued only a few hundred individual licenses — on the order of 250 a year in 2023 and 2024 — against five million affected investors. The route is real but narrow, slow and document-heavy, and for small portfolios the filing cost can outweigh the holding; some holders instead sell their exposure at a discount on the OTC secondary market.
What a private applicant needs
Judging whether a case is viable starts from a short documentary base:
- brokerage statement
- ownership structure, where the asset is held through a company, trust or nominee
Without that base there is no way to tell which regulator is competent, whether Belgium, Luxembourg or OFAC is in play, and whether the position supports a filing at all.
This material is provided for general information and is free to copy. It is not legal advice on any specific matter.