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 €202 billion of sanctioned Russian assets immobilised at Euroclear as at 30 June 2026, 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 €45 trillion by the middle of 2026.
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.
The parameters the rest of the analysis turns on:
| Legal basis | EU Regulation No. 269 (17.03.2014) freezes the assets; Regulation No. 833 (31.07.2014) adds the sectoral and banking layer. |
|---|---|
| Regulator | Belgian Treasury for Euroclear, Luxembourg Ministry of Finance for Clearstream, OFAC where a US dollar or US nexus appears. |
| Who is caught | Holders with NSD in the custody chain — about ₽5.7 trillion (over €58 billion), a fifth of it held by five million retail investors. |
| Freeze date | The EU listed NSD itself on 3 June 2022. |
| Timeline | Review runs 6–16 months, followed by an execution phase of roughly one to two months. |
| Throughput | On the order of 250 individual Belgian licenses a year in 2023 and 2024. |
| Position to date | Since November 2025 non-dollar cases proceed without an OFAC license; the sovereign immobilisation is indefinite from December 2025. |
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. €202 billion of sanctioned Russian assets sat immobilised at Euroclear at 30 June 2026 — the bulk of roughly €210 billion frozen 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, and since a February 2024 decision the net 'windfall' has been routed to Ukraine; those same revenues service the G7's Extraordinary Revenue Acceleration (ERA) loan, which is repaid from the profits rather than the principal. The money moving around the sovereign tranche stands as follows:
| Flow | Amount | Position |
|---|---|---|
| Interest earned | €2.3 billion | first half of 2026, 13% down on the year as rates fell |
| Euroclear contribution provisioned | €1.5 billion | for that same half-year |
| Paid to the EU | some €6.6 billion | in total, with a further €1.4 billion falling due in July 2026 |
| G7 ERA loan | about $50 billion | pledged in June 2024 |
| EU share of ERA | €18.1 billion | already delivered |
| Ukraine's external funding | $52.4 billion | 2025; more than 70% came through the ERA channel |
Every one of these flows comes off the assets rather than out of them.
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: an account at a bank that already has a working practice with Euroclear and Clearstream releases.
A residence track, where one is needed at all, runs in parallel: the licence application does not have to wait for it.
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.
The routes side by side
Five exits exist in practice, and they differ on the two numbers that decide the case: what the attempt costs and how long the holder waits for it.
| Route | Time | Cost | Odds | What it requires | Which positions it fits |
|---|---|---|---|---|---|
| Individual licence from the Belgian Treasury | 6–16 months of review plus 1–2 months of execution | Counsel's fee for the filing and the guarantor's due diligence; no published tariff | On the order of 250 licences a year against some five million affected holders | An EU or Swiss bank account, the custody chain per ISIN, source of funds, a European guarantor | Securities and cash in the Euroclear circuit with no US element |
| Licence from the Luxembourg Ministry of Finance | Comparable review; no published service standard | The same components, built on the Luxembourg legal basis | No published statistic | The same evidence pack, addressed to Luxembourg competence | Positions blocked in the Clearstream circuit |
| European licence plus an OFAC licence | The OFAC review runs on top of the European one | A second filing and US counsel | Almost no Russian applicant cleared this step after NSD was designated; since November 2025 non-dollar rearrangements inside Euroclear proceed without it | The European licence first, then the US application | Dollar payments, US securities, a US person anywhere in the chain |
| Sale at a discount on the OTC secondary market | Weeks | The discount itself, in place of a filing budget | Turns on finding a buyer prepared to hold a blocked position | A counterparty and a broker able to record the transfer | Small positions where the filing costs more than the holding |
| Waiting | Open-ended | Nothing in cash; the opportunity cost of the position | Depends on a delisting or a general derogation, neither of which is on the table — the sovereign immobilisation was made indefinite in December 2025 | Preserving statements and the custody map | Holders who cannot satisfy the EU-account condition, and coupons that keep accruing on the Euroclear side |
The first three rows are one route with different addressees, and the diagnosis decides which: competence follows the location of the assets, and a filing built on the wrong legal basis is refused on that ground alone. The fourth and fifth rows are the honest alternatives — the discount is a price paid once and immediately, the wait is a price paid in time with no guarantee at the end of it.
The arithmetic of the choice is blunt. The filing cost barely scales with the size of the position: the same custody map, the same source-of-funds file and the same guarantor are needed for a six-figure portfolio and for a seven-figure one, so below a certain size the licence route consumes the asset it is trying to free. That threshold is individual, but it is what pushes retail holders towards the discount, and it is why the licence channel, with a few hundred decisions a year, has never been a mass remedy.
One sequencing rule follows from the table. The diagnosis — custody map, sanctions check on every participant, and a receiving account a bank has already agreed to — comes before the choice of route, because it is the same work in all five rows. A holder who has it can price the licence against the discount; a holder who does not has nothing to compare.
Six settlement houses, six freeze logics
Euroclear and Clearstream are where the Russian private tranche got stuck, but a cross-border portfolio usually touches more than two depositories. Whether a position can be frozen, by whom, and through which channel it comes out depends on the house at the bottom of the chain and on the law that governs the holder's right there. The six that matter most for a private holder with a Russian nexus compare as follows.
| Depository | Role and home law | What the holder owns | Who can freeze the position | Russian nexus today | Release channel |
|---|---|---|---|---|---|
| Euroclear Bank (Belgium) | ICSD; Royal Decree No. 62 of 1967 | A co-ownership right in a fungible pool, recoverable if an intermediary fails | EU Regulations 269/2014 and 833/2014, applied by the Belgian Treasury | NSD's account frozen since 3 June 2022 | Belgian Treasury licence; OFAC only where a US element appears |
| Clearstream Banking (Luxembourg) | ICSD; Law of 1 August 2001 on the circulation of securities | An intangible property right in the pool, with a right of recovery | The same EU regulations, applied by the Luxembourg Ministry of Finance | NSD's account frozen since 3 June 2022 | Luxembourg Ministry of Finance authorisation |
| NSD (Russia) | Russian central depository; Federal Law No. 414-FZ of 2011 | A book entry in a Russian depository that itself holds abroad | The EU and Switzerland (listed June 2022), OFAC (designated 12 June 2024); Russia's own type C accounts on the outbound side | It is the nexus | Western licences for the foreign leg; Russian exchange rounds under Decree No. 844 for the domestic leg |
| SIX SIS (Switzerland) | Swiss CSD; Federal Intermediated Securities Act | Intermediated securities kept outside the custodian's estate (art. 17 FISA) | SECO under the Ukraine ordinance (SR 946.231.176.72) | NSD in Annex 8 since 10 June 2022 | SECO exception |
| DTC (United States) | US CSD; positions registered to the nominee Cede & Co. | A security entitlement under UCC Article 8 against the broker | OFAC: SDN listing and the 50% ownership rule | NSD, Moscow Exchange and NCC on the SDN list since 12 June 2024 | OFAC specific licence |
| CDP (Singapore) | SGX central depository | Shares recorded in the investor's own name in a direct account | MAS measures of March 2022 aimed at four named banks and sovereign fundraising | None by nationality; only a designated bank in the chain | No private-holder freeze channel to use |
The table separates two things that are often merged. A freeze by listing hits whatever a named person holds — NSD, a sanctioned bank, a designated individual — wherever it sits; a freeze by status comes from sectoral rules that bar services to Russian persons without naming anyone. The EU and Switzerland apply both: article 5e of Regulation 833/2014 forbids any EU central securities depository to provide services for transferable securities issued after 12 April 2022 to Russian nationals, residents or entities, whether or not NSD is anywhere near the position; the ban does not reach Russian nationals who hold an EU, EEA or Swiss passport or residence permit. The United States and Singapore freeze only by listing. A Russian national holding US shares directly at a US broker, with no designated person in the chain, is not blocked by US law for that reason alone — what stops such accounts in practice is the broker's own risk appetite, not a regulation.
The US regime also treats frozen money differently. Under 31 CFR 587.203 a US person holding blocked funds must keep them in a blocked interest-bearing account at a commercially reasonable rate, in instruments of no more than 180 days, and must report the blocking to OFAC within ten business days under 31 CFR 501.603. Blocked cash in the US therefore grows while it waits; the EU regulations contain no equivalent duty toward a private holder.
The Russian side is not a mirror of the Western one. Since March 2022 payments to non-residents from "unfriendly" states run into type C accounts, from which money cannot leave Russia freely. For residents, Decree No. 844 provided an exchange route for certain blocked foreign securities, subject to a ₽100,000 per-investor limit. The transaction organiser reported in October 2025 that it had executed transactions totalling about ₽10.6 billion under that decree. Availability and terms of any new exchange require a current organiser notice.
Holder profile → route
| Profile | Where the position sits | First route | Fallback |
|---|---|---|---|
| Retail holder with a small position at a Russian broker | NSD → Euroclear or Clearstream | A future domestic exchange round, if one opens | Sale at a discount or waiting |
| Larger non-dollar portfolio, EU bank account available | NSD → Euroclear | Belgian Treasury licence, no OFAC step since November 2025 | Sale at a discount |
| Same profile, Luxembourg-held bonds | NSD → Clearstream | Luxembourg Ministry of Finance | Sale at a discount |
| US securities or dollar cash flows in the chain | NSD → Euroclear or Clearstream → DTC | European licence, then an OFAC specific licence | Waiting, with the US leg earning interest if blocked there |
| Portfolio booked at a Swiss bank, no Russian depository | Swiss bank → SIX SIS | No licence needed unless the holder or an issuer is listed; the service and deposit limits still apply | SECO exception for a listed element |
| Singapore shares in a CDP direct account | CDP | Nothing to unblock unless a designated bank sits in the chain | — |
The practical order follows from where the chain breaks. A holder with a Russian depository anywhere in the chain works through the Belgian or Luxembourg licence first and adds OFAC only for a genuine US leg. A holder whose assets never passed through NSD usually has no freeze to lift at all and is dealing instead with service bans and bank de-risking, which are answered by moving the booking centre rather than by a licence application.
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.
Q/A
Does a Euroclear or Clearstream freeze mean that ownership has been lost?
No. Freezing prevents movement, use or alteration of frozen funds, but does not by itself transfer ownership to a state or depository. The legal owner of each security and the precise custody-chain level at which the prohibition arose must still be established.
Can a private investor simply ask Euroclear to release the assets?
Usually not. The holder works through its broker or custodian and documents the full custody chain. Assets frozen in Belgium cannot be released without Belgian Treasury authorisation; the application must identify the legal ground, parties, amount, institutions and supporting evidence.
Is one Belgian authorisation enough to execute the transfer?
Not always. An authorisation operates only within its stated regime, transaction, amount, parties and conditions. A broker, receiving bank or another link may face a different EU, UK or US prohibition, so every relevant jurisdiction and permission must be mapped before filing.
Does changing citizenship or tax residence automatically unblock the assets?
No. Sanctions analysis considers listing, ownership and control, the origin and timing of rights, the transaction route and every intermediary involved. A new passport or address may be evidence, but it does not replace a licensing ground or custody-chain review.
Which route makes sense for a small position?
The filing cost hardly depends on the size of the holding, so on small positions the licence route can cost more than the asset it frees. The practical options there are a sale at a discount on the secondary market, or waiting with the documents preserved. The comparison is made once the custody map exists: without it the discount cannot be priced against the filing.
What information is needed before selecting an unblocking route?
Build a custody map for every ISIN: owner, broker, national depository, Euroclear or Clearstream, cash account and proposed recipient. Add statements, contracts, acquisition dates, amount, currency and the sanctions status of each participant; without that record the competent authority cannot be identified reliably.
Are securities at SIX SIS, DTC or CDP frozen simply because the holder is Russian?
Not by listing. The United States and Singapore freeze only what a designated person owns or controls, so a position with no sanctioned participant in the chain is not blocked there. Switzerland, like the EU, adds status-based limits on services to Russian persons, and every broker applies its own risk policy on top of the law.
Why does blocked cash in the United States earn interest?
OFAC requires a US holder of blocked funds to keep them in a blocked interest-bearing account at a commercially reasonable rate, in instruments of no more than 180 days (31 CFR 587.203). The EU regulations impose no comparable duty toward a private holder, so the same dividend blocked in Brussels and in New York ages differently.