Securities held through the Russian depository NSD were frozen at Euroclear and Clearstream in June 2022. Investors who are not sanctioned can apply for a licence to the Belgian Treasury or the Luxembourg Ministry of Finance. The file needs the full custody chain, proof of ownership, screening of all parties and an EU or Swiss receiving account. Reviews take six to sixteen months. EU citizenship or residence helps; for small positions a sale can be more rational.
Your shares are frozen because the depository is
Millions of private investors who bought foreign shares and bonds through Russian brokers found their positions frozen in 2022. The investors were not sanctioned; the Russian depository that held the securities in Euroclear and Clearstream was. Since then, Belgium and Luxembourg have released positions one licence at a time.
The process is legal, slow and document-heavy. The authority needs to see the full custody chain, proof that you own the securities, that no sanctioned person benefits, and a clean account in the EU or Switzerland to receive them.
Belgian Treasury
Licences for positions held in Brussels.
Luxembourg Ministry of Finance
Licences for positions held in Luxembourg.
OFAC
Separate licence when dollars or US persons are involved.
6 to 16 months
Plus 1 to 2 months to execute.
Legal basis and who can apply
| Issue | Rule | Practice |
|---|---|---|
| Freeze | NSD listed under Regulation 269/2014 on 3 June 2022 | Everything NSD held for its clients is frozen |
| Release | Derogations in Article 6b of Regulation 269/2014 granted by the national authority | Licence per ISIN, amount and receiving account |
| Russian residents | Article 5e of Regulation 833/2014 limits EU depository services for securities issued after 12 April 2022 | Holders with EU or Swiss citizenship or residence permits are outside that restriction |
| Receiving account | Must be with an EU or Swiss bank or broker | No transfer to Russian intermediaries |
| Reporting | Article 6b and 8 duties of EU operators | Authorities check the chain with Euroclear or Clearstream |
Law and practice: Regulation 269/2014 (asset freeze) and Regulation 833/2014 (sectoral measures), including Article 5e; the Commission's FAQs on asset freezes. Licences are discretionary and case by case; refusals can be challenged before the national courts and questions on interpretation reach the Court of Justice through preliminary references. The figures on timing come from practice, not from the law.
What the authority wants to see
- Custody chain. Every intermediary from your broker to NSD to Euroclear or Clearstream, per ISIN.
- Ownership. Broker statements on the freeze date and today; for companies, the ownership chart to the last natural person.
- No sanctioned benefit. Screening of you, the broker and every party in the chain.
- Source of funds. How the securities were bought.
- Receiving account. Confirmation from an EU or Swiss bank or broker that it will accept the transfer.
- Representation. A European lawyer who files, answers questions and follows the execution.
A Russian citizen with a Spanish residence permit holds EUR 240,000 of US and German shares through a Russian broker, frozen at Euroclear. We map the chain per ISIN, collect the broker statements and the Spanish permit, screen all parties, and open a receiving account at an EU broker. The Belgian Treasury asks two rounds of questions; the licence follows after eleven months and the transfer after six weeks.
Which route fits your blocked securities?
The result updates with each answer.
Which route fits your blocked securities?
Five questions about you and your portfolio. You see the likely route, the authority and what to prepare.
The custody chain decides the route.
Brussels and Luxembourg.
EU residence opens doors.
Small positions may not justify a file.
Frozen securities at Euroclear and Clearstream: frequent questions
Why are my securities frozen if I am not sanctioned?
Because the Russian National Settlement Depository (NSD) is. NSD was listed by the EU on 3 June 2022, so the securities it held at Euroclear and Clearstream for Russian brokers' clients were frozen with it, regardless of who the end investor is.
Who decides on a release?
The national competent authority of the depository's country: the Belgian Treasury for Euroclear and the Luxembourg Ministry of Finance for Clearstream. Each licence is specific to the securities, the amount and the parties.
How long does it take?
Experience shows six to sixteen months for the review and one to two months to execute after the licence, depending on the completeness of the file and the custody chain.
Is it worth it for a small portfolio?
The cost of building the file does not grow much with the size of the portfolio. Below roughly EUR 100,000 a sale at a discount or waiting can be more rational. We check this before you file.
Do I also need a US licence?
If US dollars or US persons are in the chain, OFAC rules apply. Non-dollar positions within Euroclear with no US participant can, in recent practice, be released without a separate OFAC licence.