Blog · 2026-08-06

Unblocking frozen brokerage assets in 2026

Which unlocking routes actually work in 2026, what they cost, and how to avoid losing your money a second time

In March 2022, Euroclear and Clearstream stopped processing transactions for Russia's National Settlement Depository (NSD), and on June 3, 2022 the EU placed NSD under blocking sanctions. The result, by the Russian central bank's late 2022 estimate: RUB 5.7 trillion of investor assets frozen, with just over 20% belonging to retail investors. Four years on, the picture is better than most people assume. Roughly half of retail investors' assets have been released, since late 2025 Euroclear has been unblocking positions under a Belgian license alone, without US approval, and Russian courts are ruling against the depository on an industrial scale. Here is an honest breakdown of what actually works in 2026, what it costs, and which schemes make people lose their money twice.

Who is stuck, and why

The classic custody chain for a foreign security held with a Russian broker looked like this: broker - Russian depository - NSD - Euroclear (Belgium) or Clearstream (Luxembourg). When the EU sanctioned NSD, the European depositories froze everything held through its accounts: foreign stocks, eurobonds, ETFs, depositary receipts. The securities are still legally yours - they sit on the accounts, but any transaction requires a European regulator's permission.

SPB Exchange is a separate track. In November 2023, OFAC added it to the SDN list, so securities held through SPB Bank outside the NSD chain are frozen under US law. Different regulator, different licenses, different dynamics: in April 2025 the exchange and SPB Bank filed a joint petition to be removed from the sanctions list, and lawyers put the odds of a partial unblocking in 2026 at 40-50%. If your assets are stuck there, the European mechanisms will not help you - watch OFAC instead.

Timeline: from the freeze to the first returns

What actually works in 2026

An individual license from the Belgian treasury

This is the main working tool for anyone with a meaningful amount frozen. The logic: you prove to the Belgian treasury (or Luxembourg's, for Clearstream) that you are not sanctioned, that you are the ultimate beneficial owner of the assets, and that once released, the securities will move to an account outside the sanctions perimeter.

The key change of late 2025: Euroclear began releasing assets on the basis of a Belgian license alone, without a license from OFAC - provided no US counterparties are involved and the assets move within the Euroclear system. Before that, the de facto requirement of a double approval killed most cases. Lawyers and brokers have confirmed successful cases under the new approach, but Euroclear clears every case individually through its own compliance.

Timing and odds: the minimum review period is around 14 months, and the process typically takes one to two years. Lawyers put the probability of success anywhere from 5% to 50% depending on how clean the case is: provenance of the assets, no sanctioned persons in the ownership chain, quality of the paperwork.

One practical requirement people remember too late: the license permits a transfer, but the assets need somewhere to go. You need an account with a foreign broker or bank that has Euroclear access and is willing to accept Russian-origin assets and run them through its compliance. Opening such an account without residency abroad or a second passport is hard, so the infrastructure should be in place before you file - we cover how this works on our personal accounts abroad page, and for companies and holding structures on the business accounts page.

Russian courts

Since October 2024, arbitration courts in Moscow, St Petersburg and Tatarstan have been consistently granting investors' claims against Euroclear: the courts find that the depository is unlawfully withholding funds and order recovery out of Euroclear's assets held in Russia. There are 47 enforcement proceedings against the depository, with both individuals and asset managers among the claimants.

The downsides are obvious. You recover rubles from a limited pool of Euroclear's Russian assets, and that pool is not bottomless: in May 2026 a court awarded the Russian central bank about EUR 200 billion against Euroclear with immediate enforcement, so competition for the depository's assets has exploded. The second downside: Euroclear sees Russian litigation and takes it into account when reviewing unblocking applications, so the court route and the license route conflict with each other. Pick your strategy with lawyers who handle both types of cases - we list vetted ones on our lawyers page.

What is already exhausted or nearly closed

• The Decree 844 swap: the two 2024 rounds returned RUB 10.64 billion to investors - less than a third of the applications filed. New rounds are being discussed, but none has run since autumn 2024.
• Decree 665 payouts: coupons, dividends and redemptions on frozen securities were paid out in rubles, and the program wrapped up in September 2024. An extension covering newly accrued income is under discussion.
• Selling frozen securities over the counter: it works, but at a deep discount and with legal risks for both sides. An option for those who need cash now, at any price.

What unblocking costs on the market

Simple arithmetic: if you have less than RUB 5-7 million frozen, an individual license will almost certainly not pay for itself. For portfolios that size, the realistic options are litigation, a discounted sale, or waiting for political decisions. For portfolios from EUR 100,000 upward, the license is the main route.

And do not forget taxes: Decree 665 payouts, sales of released securities and post-release coupons are all taxable events, and the rules differ if you are no longer a Russian tax resident. You can compare rates by country in our tax guide.

The scam industry around unblocking

The Russian central bank warned about unblocking scams as early as January 2024, and there are more of them now, not fewer. The typical scripts:

• A call from someone posing as your broker, the central bank or a government portal: your assets have already been released, you just need to pay a fee or move money to a safe account.
• A demand to deposit an amount equal to the value of your frozen assets, supposedly to confirm ownership or secure the deal.
• A guaranteed 100% unblocking in 2-3 months. The real Belgian license timeline starts at 14 months, and nobody can guarantee anything.
• Fake law firms with throwaway websites: they collect an upfront fee and vanish, or collect passports and powers of attorney and then dispose of your securities.
• An offer to transfer your securities to someone else's account to speed things up. Assets transferred this way are gone.

Basic hygiene: the permission is issued by the Belgian treasury, not by any intermediary; no intermediary can guarantee anything; check lawyers against bar registers and real court records; never pay a success fee upfront; never sign a general power of attorney over your assets.

A short plan for 2026

• Take inventory: find out from your broker exactly where the securities are frozen - in the NSD chain (the European track) or at SPB Bank (the US track). The routes are fundamentally different.
• Run the numbers: below RUB 5-7 million, a license will not pay off; above that, model your specific case with a lawyer.
• Build the infrastructure: open the foreign account that will receive the assets before you file the application.
• Pick one strategy - license or Russian court - and do not mix them without understanding the consequences.
• Stay on top of the news: the late 2025 mechanism showed the rules can change fast, and the EUR 200 billion court award to the Russian central bank, together with the EU debate on a reparations loan for Ukraine, could swing things in either direction.

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