Author: Alena Dunaeva
Attorney, Family Office
Since 2022 Russian investors have been engaged in disputes with the European depositories Euroclear and Clearstream over frozen assets. To transfer frozen securities an individual licence is required from the relevant regulators: the Belgian Treasury, the Ministry of Finance of Luxembourg, and/or OFAC. As of 2025 approximately 50% of frozen assets have been unfrozen under individual licences, amounting to a total of ₽570 billion.
Grounds
EU — Regulation No. 269 (17.03.2014):
Blocking sanctions against certain individuals and banks holding accounts with Euroclear. Freezing of assets held by the National Settlement Depository (NSD), and prohibition on disposing of securities and proceeds on segregated accounts.
EU — Regulation No. 833 (31.07.2014):
Prohibition on deposits exceeding €100,000 from Russian persons. Euroclear interprets the restrictions broadly, refusing transfers and distributions even where NSD is not involved in the custody.
United States and United Kingdom:
Euroclear applies OFAC and HM Treasury sanctions. In many cases an individual licence from the respective foreign regulators is required.
Client Profile
We assist investors whose assets are frozen on the accounts of brokers such as:
- Alfa-Bank
- Bank DOM.RF
- Rosbank
- Citibank
- SPB Exchange
- Tinkoff
Unfreezing Mechanism
To obtain an individual licence from the regulator and restore access to frozen securities the following requirements must be met:
- hold a bank account in the European Union or Switzerland
- provide documentation evidencing source of funds and ownership structure
- engage a European guarantor
Possession of an EU residence permit or passport significantly simplifies the unfreezing process and facilitates opening of a European bank account.
Stage 1. Residence permit and account opening
We provide assistance with expedited Spanish residence permit (Digital Nomad) and opening of a bank account with Caixa Bank, where a working process with Euroclear and Clearstream is already established.
Services include:
- preparation of the application package for the Digital Nomad residence permit;
- obtaining NIE and tax identification number;
- registration of address in the EU;
- opening of a personal bank account in the EU;
Timeline: approximately 3 months
Licence application may be initiated in parallel with the residence permit process.
Spain — Residence Permit Digital Nomad
Stage 2. Submission of individual licence application
At this stage, we prepare the legal rationale and application package for submission to:
- Belgian Treasury (for Euroclear)
- Luxembourg Ministry of Finance (for Clearstream)
- OFAC (if the structure involves US dollar exposure or sanctioned links)
Timeline: 6–16 months
We engage a professional guarantor — a lawyer or financial intermediary in the EU who issues a favourable opinion on your asset portfolio and supports the licence application.
Stage 3. Asset transfer
Upon issuance of the licence, we assist with its execution:
- coordination with broker and bank regarding transfer of securities or funds
- fulfilment of licence conditions (including reporting obligations)
- submission of transfer instructions for securities or cash distributions
- ongoing interaction with guarantor and regulator
Timeline: 1–2 months
Commencement of Services
To assess the prospects and initiate work the following documents are required:
- brokerage statement
- ownership structure (if the asset is held through a company / trust / nominee)
Once these documents are provided we will prepare a project roadmap and cost estimate.
Contact Information
If you have any questions or require a consultation, our experts will be happy to assist you.
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