🇪🇺Euroclear and Clearstream – Unfreezing assets

Lawyer, Family Office

Since 2022, Russian investors have been contesting frozen assets with European depositories Euroclear and Clearstream. Transferring frozen securities requires an individual license from regulators: the Belgian Treasury, Luxembourg Ministry of Finance and/or OFAC. As of 2025, individual licenses have unfrozen approximately 50% of blocked assets totaling ₽570 billion.

Reasons

EU — Regulation No. 269 (17.03.2014):

Blocking sanctions against individuals and banks holding accounts with Euroclear. Freezing of NSD assets, prohibition on disposing of securities and payments in segregated accounts.

EU — Regulation No. 833 (31.07.2014):

Ban on deposits from Russian persons exceeding €100,000. Euroclear interprets restrictions broadly, refusing transfers and payments even when NSD is not involved in custody.

US and UK:

Euroclear applies OFAC and HM Treasury sanctions. In certain cases, an individual license from foreign regulators is required.

Client profile

We work with investors whose assets are blocked in broker accounts, such as:

• Alfa-Bank
• Bank Dom.RF
• Rosbank
• Citibank
• SPb Exchange
• Tinkoff

Unfreezing mechanism

To obtain an individual regulatory license and regain access to frozen securities, the following criteria must be met:

• have a bank account in the EU or Switzerland
• provide documentation on source of funds and asset ownership structure
• engage a European guarantor

💬 Having an EU residence permit or passport significantly simplifies the unfreezing process and allows opening a European bank account.

Stage 1. Obtaining residence permit and opening account

We support obtaining a fast-trackSpanish residence permit (Digital Nomad)and opening an account withCaixa Bank, which has already established a practice of working with Euroclear and Clearstream.

What's included:

• preparation of Digital Nomad residence permit documentation;
• obtaining NIE and tax number.
• registration of EU address;
• opening personal account in EU bank;

Timeline: ~3 months

💬 License application can begin in parallel with obtaining residence permit.

Stage 2. Filing for individual license

At this stage we prepare legal grounds and documentation package for filing with:

• Belgian Treasury (for Euroclear)
• Luxembourg Ministry of Finance (for Clearstream)
• OFAC (if US dollar involved in structure or sanctions nexus exists)

Timeline: 6–16 months.

💬 We engage a professional guarantor — a lawyer or financial intermediary in the EU who prepares a positive opinion on your asset portfolio and supports the license filing

Stage 3. Asset transfer

After license issuance, we support its execution:

• coordination with broker and bank on transfer of securities or funds
• compliance with license conditions (including reporting)
• filing instructions for transfer of securities or cash payments
• liaison with guarantor and regulator

Timeline: 1–2 months.

Getting started

To assess prospects and begin work, the following documents are required:

• brokerage statement
• ownership structure (if asset is held through company / trust / nominee holder)

Upon provision of the above documents, we will prepare a project roadmap and calculate costs.