The path to unlocking frozen assets for non-sanctioned investors in Russia and Europe

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The Central Bank of Russia says that investors who are not listed on sanctions by foreign depository institutions may see their frozen assets unfrozen sooner. This position was shared by Vladimir Chistyukhin, the First Deputy Governor of the Central Bank, and was reported by TASS.

Regulators Euroclear and Clearstream are reviewing unobstructed transfer and release options. They are examining the possibility of freeing assets held by individuals who are not subject to sanctions. In essence, the discussion centers on lifting blocks for those who are not restricted, while sanctions remain in place for sanctioned parties. The central bank expresses guarded optimism that authorities will move forward with a measured approach to avoid unintended consequences while aiming to help unblocked rightful holders. The hope is that the responsible bodies will demonstrate the resolve to act in the near term, as reported by TASS and reiterated in subsequent coverage.

In June 2022 the European Union imposed restrictive measures on the National Reconciliation Agency, known as NSD. At that time, NSD faced sanctions from international depositories Euroclear and Clearstream since February 2022, which froze certain Russian investors’ securities and documents. This broader framework has shaped how assets are processed and guarded across cross-border clearing systems, influencing compliance and asset custody decisions for market participants.

Earlier this year, reports from RBC indicated that the Bank of Russia uncovered cases of illegal deletion of foreign securities from Russian depositories abroad. These findings raise concerns about data integrity and the handling of foreign holdings, underscoring the need for transparent procedures in cross-border asset administration and clearance.

Additionally, the Luxembourg Ministry of Finance took steps in December to enable the unlocking of some NSD holdings held in the Clearstream international custodian. This move reflects a broader trend toward clarifying asset custody arrangements and addressing legacy restrictions that affect market access for certain investors.

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