According to the latest figures from the Ministry of Finance, €5.5bn of Russian assets are currently in escrow. (Photo: Maison Moderne/Archives)

According to the latest figures from the Ministry of Finance, €5.5bn of Russian assets are currently in escrow. (Photo: Maison Moderne/Archives)

While the ministry of finance has just made public the procedure for derogation from the EU sanctions regimes against Russia, the quantity of blocked assets is rising sharply. 

As of 25 November, according to the declarations made by the countries to the Commission, “declarations of unequal quality” said European Commissioners Didier Reynders (Justice) and Mairead McGuinness (Financial Services), €18.9bn had been blocked at EU level. The figure is now close to €20bn.

The most successful countries are Belgium with €3.5bn seized, followed by Luxembourg with €2.5bn, Italy (€2.3bn), Germany (€2.2bn), Ireland (€1.8bn), Austria (€1.8bn), France (€1.3bn) and Spain (€1bn).

These amounts do not seem to correspond to the reality on the ground. At least for Luxembourg where, according to figures confirmed by the ministry of finance to Paperjam on 22 December, €5.5bn are currently sequestered. That is €1.3bn more than last June. This increase can be attributed to the various new sanction packages that have followed one another since the summer.

Unlocking under strict conditions

It is in this context that the ministry has published the general procedure to be followed to unfreeze these assets.

A procedure strictly framed by the European Council Regulation 269/2014. A procedure that does not aim to circumvent the sanctions, but whose philosophy is to facilitate the closure of business relationships with any of the 1,241 persons or 118 entities currently targeted by the sanctions.

And more specifically with the National Settlement Depository (NSD), the Russian payment agency equivalent to Clearstream or Euroclear used by Moscow to service the country’s Eurobonds and targeted by the European sanctions on 3 June. This concerns business relationships started before 3 June 2022 and which must be closed by 7 January at the latest. According to the Reuters news agency, the procedure should allow non-sanctioned Russian investors to transfer assets from the sanctioned NSD to other locations.

Despite what a Reuters report published on 20 December from Moscow might have suggested, no assets have been released to date. This was confirmed by the finance ministry to Delano’s sister publication Paperjam, even though “several requests are being processed.” These are necessarily sensitive requests at a time when the war is likely to get bogged down and military operations on the ground will be greatly slowed down due to winter.

This story was first published in French on . It has been translated and edited for Delano.