Law and act: will the Central Bank be able to return the funds frozen in Euroclear
The decision of the Moscow Arbitration Court in favor of the Bank of Russia in the case of the freezing of about €200 billion in the European depository Euroclear, although it still looks poorly implemented, is in fact another necessary step on a long bureaucratic path. Lawyers interviewed by Izvestia believe that the case will stand still in the next year and a half: the defendant will begin to appeal to courts of various instances in the Russian Federation, but their position is likely to remain unchanged. And only then will the Central Bank of the Russian Federation be able to go to other jurisdictions. Moreover, our requirements are unlikely to be satisfied in the EU, so we will need to consider other countries, such as Hong Kong or the UAE. However, it will be difficult to prove your case there either. Izvestia investigated the real chances of the Russian regulator to return the blocked assets.
What is the Central Bank of the Russian Federation trying to achieve
The Moscow Arbitration Court has fully satisfied the claim of the Bank of Russia against the Belgian depository Euroclear Bank for the recovery of 18.17 trillion rubles. losses. The case was considered behind closed doors, so the details were not disclosed.
The Central Bank told reporters that they were satisfied with the decision. However, they clarified that it has not yet entered into force and the defendant has the right to challenge and file an appeal.
— It is premature to talk about how the court's decision will be enforced, since it has not yet entered into force. At the same time, we continue to work to challenge the illegal actions of the European Union in relation to the sovereign assets of the Bank of Russia," the representative of the regulator added.
The Central Bank filed a lawsuit against Euroclear in December 2025 against the background of the European Union's plans to use blocked Russian assets to finance Ukraine. At that time, the decision on the "reparation loan" was not supported, but the EU agreed to an indefinite freeze of Russian reserves.
The head of the Central Bank, Elvira Nabiullina, commented only in general terms on why the lawsuits were filed with such a delay — only at the end of 2025.
— Why did we file a lawsuit now, and not earlier? There were circumstances for this, which it will be appropriate to talk about later. And what will happen next, how the court's decision will be executed, will be determined after the court's decision comes into force," she said.
The amount of the claim against Euroclear is 18.2 trillion rubles — this amount includes frozen funds, the value of blocked securities, as well as lost profits. In total, the EU and the G7 countries have frozen about €300 billion of Russian assets. About 180 billion euros, the main part, is stored in the Belgian Euroclear depository.
At the same time, the defendants' side has already stated that it intends to appeal the decision of the Arbitration Court. Euroclear lawyers Maxim Kulkov and Sergey Saveliev told reporters that the right to a fair trial was clearly violated.
Reference. In parallel with the Russian courts, the Bank of Russia is already waging a separate legal battle in Europe. On February 27, 2026, the Central Bank filed a lawsuit with the General Court of the European Union in Luxembourg. There, Russia is challenging the mechanism of indefinite asset blocking and is trying to prove a violation of property rights, principles of judicial protection and norms of international law.
Why did the Central Bank decide to act through the courts
The decision of the Moscow Arbitration Court by itself does not return the frozen assets to the Central Bank, the head of the international service explained to Izvestia. Razmorozka.com , Belgian lawyer Alexey Bogdanov. But it turns the dispute from an abstract sanctions conflict into a concrete monetary demand for hundreds of billions of euros.
The Central Bank prefers the judicial path for two reasons, according to independent expert Andrei Barkhota. First, if you sit back, the leadership of the Bank of Russia can be accused of complicity with the European financial system. The second factor is related to the fact that the megaregulator often focuses on the regulatory aspect in its policy, because a number of top managers of the Central Bank are root lawyers.
The judicial practice of filing lawsuits in the Russian jurisdiction already exists — claims against Euroclear from NCC, private investors, management companies and financial structures have already been considered here, Alexey Bogdanov recalled. The most famous example is Alfa—Capital. In 2026, the Moscow Arbitration Court recovered more than 15 billion rubles from Euroclear in one of the company's lawsuits. At the same time, larger claims were previously rejected. That is, the practice is still heterogeneous.
— Nevertheless, its presence is important for Europe. If such decisions were isolated, they could be ignored as political noise. But now an array of judicial acts against the European infrastructure is beginning to take shape," Alexey Bogdanov believes.
At the same time, he stressed that the main difficulty arises not at the stage of obtaining a decision in Russia, but at the stage of its execution abroad. To date, there is no public information that the Russian plaintiffs have finally managed to recover large sums from Euroclear in foreign jurisdictions.
What will be the next steps to unfreeze assets?
Financial lawyer Olga Plekhanova is confident that Euroclear will go through the entire Russian procedural ladder in order to overturn the decision of the Arbitration Court. That is, the European depository is likely to appeal, appeal, and reach the Supreme Court of the Russian Federation.
— The decision of the first instance was rendered in about 5 months, which is extremely fast for such a complex international dispute. From the point of view of Russian procedural terms, an appeal may take several months, and cassation may take several more. If Euroclear reaches the Supreme Court, the whole cycle can last for a year and a half," Olga Plekhanova estimated.
However, in her opinion, the probability that the Russian courts will radically change their position is low. Most likely, Euroclear will lose at all stages. And the main front of the dispute will gradually shift beyond Russia.
— Unfortunately, the prospects within the EU are extremely limited. The European courts will assume that the dispute is directly related to the sanctions regime and public order issues. Therefore, the decision of the Arbitration Court is not recognized there," the lawyer believes.
Then the Russian Central Bank will most likely have to look for other jurisdictions where Euroclear may have assets, funds or property rights in order to recover them in favor of executing the decision. First of all, we are talking about Hong Kong, the United Arab Emirates and other financial centers that are not part of the European sanctions system, Olga Plekhanova believes.
— Hong Kong looks like the most interesting option. Its justice system allows recognition of foreign judgments even in the absence of a special international agreement with Russia. However, this does not mean automatic execution. The Bank of Russia will have to initiate a separate lawsuit already in Hong Kong and prove that the Russian decision complies with the requirements of local legislation," she explained.
However, in the end, the main problem will not even be in the trial itself, but in who exactly will risk participating in the execution of the decision against the largest European depository, Olga Plekhanova described the prospects. Any banks, depositories or financial intermediaries will take into account the possible consequences from the EU and the United States. And it was the prospects of implementing the Russian courts' decisions in third countries that forced the European Union to start building a new protective circuit: the 20th package of sanctions is actually aimed at attempts to enforce Russian decisions outside the EU.
Is it realistic to recover the funds frozen in Euroclear
Right now, the probability of a full real penalty is low, Anastasia Feinberg, a consultant at the Estonian Legal Alliance, warned. But this does not mean that the lawsuit is meaningless. The court decision already creates political pressure, legal risk, a negotiating asset, a threat of execution in third countries and reputational problems for Euroclear.
The latter is perhaps the most important thing: for a world—class depository, it is much more dangerous to lose trust and the status of a neutral infrastructure.
A political settlement of the conflict in Ukraine currently looks like the most realistic option to solve the problem of frozen reserves, said Evgenia Amelkina, Director of the Eastern Legal Alliance.
If serious de-escalation begins, the issue of assets will almost inevitably become part of the overall negotiating package. In this case, various options are possible: partial unblocking of funds, offsetting of claims, creation of special compensation mechanisms or other forms of settlement.
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