# Euroclear and Clearstream – Unfreezing assets > Blocked Russian securities at Euroclear and Clearstream: individual licenses from Belgium, Luxembourg and OFAC in a three-stage HNW roadmap. Author: Ксения Воронова — юрист, Family Office (https://wiki.private.law/authors/voronova) Last modified: 2026-06-04T06:11:00.000Z Canonical: https://wiki.private.law/en/euroclear-clearstream Topics: investments Jurisdictions: luxembourg, russia Functional tags: wealth-planning Semantic tags: wealth-planning --- Lawyer, Family Office --- > 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 (to be verified as the position evolves). # 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 makes the rest realistic — above all it makes a European bank account obtainable, and the whole process depends on having one. ### Stage 1. Obtaining residence permit and opening account The practical first move is to gain a foothold inside the EU. Spain's [Digital Nomad permit](https://wiki.private.law/en/digital-nomad-visas) is a common fast-track, paired with an account at a [bank](https://wiki.private.law/en/private-banking) that already has a working practice with Euroclear and Clearstream releases — CaixaBank among them. This stage covers: - 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 Stage two assembles the legal grounds and the documentation package filed with the competent regulators: - 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. 💬 A professional guarantor — an EU lawyer or financial intermediary — usually prepares a positive opinion on the portfolio and stands behind the filing. ### Stage 3. Asset transfer Once the license is issued, execution follows: - 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. > 💡 Since November 2025 Euroclear has allowed releases without a US (OFAC) license where no US person or institution is involved and the securities are merely rearranged within Euroclear, provided the holder already holds a Belgian Treasury license. That removes the single biggest blockage for non-dollar portfolios — the OFAC step that almost no Russian applicant had cleared since NSD was sanctioned. 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](https://wiki.private.law/en/otc). # 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](https://wiki.private.law/en/holding-structures) From that base a realistic roadmap and a cost estimate can be drawn — and, just as often, a candid view of whether the case is worth filing at all. --- > 🍓 Two regimes wear one name here. The sovereign tranche at Euroclear is a geopolitical instrument whose fate is settled in Brussels, beyond the reach of any single investor. The private tranche behind NSD is, at bottom, a paperwork problem with a slow but genuine exit — a national derogation, and since late 2025 one that no longer always runs through Washington. *This material is provided for general information and is free to copy. It is not legal advice on any specific matter.* Related links: [OTC market](https://wiki.private.law/en/otc) · [Private banking](https://wiki.private.law/en/private-banking) · [Digital nomad visas](https://wiki.private.law/en/digital-nomad-visas) · [Holding structures](https://wiki.private.law/en/holding-structures) · [Succession planning](https://wiki.private.law/en/succession-planning) · [Luxembourg banking](https://wiki.private.law/en/banking-luxembourg) · [Euroclear (official)](https://www.euroclear.com/) · [EU sanctions against Russia](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/) --- ## Factual claims - Lawyer, Family Office - 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). - 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. - EU — Regulation No. - EU — Regulation No. - Sectoral measures, including the ban on accepting deposits above €100,000 from Russian persons. - 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. - Timeline: ~3 months