Doom money: Russians massively challenge Belgium's refusals to unlock assets
Russians are massively appealing against the refusals of the Belgian authorities to unlock assets, Izvestia found out. We are talking about private investors whose securities and money are stuck in the Euroclear depository due to EU sanctions. In December and January, the number of appeals increased dramatically: investors increasingly go to the Belgian Council of State, trying to challenge the incorrect decisions of the Ministry of Finance of the country. And, apparently, the complaints have worked: the Belgian Treasury has already announced the suspension of the practice of refusing licenses to unlock assets, and the system will be reviewed. Whether this applies to everyone and how much it costs to get your money back is in the Izvestia article.
How Russians are trying to unblock their assets in the EU
The Russians are massively appealing the refusal of the Belgian authorities to return the blocked assets placed in the Euroclear depository, Izvestia found out. According to law firms, the number of such applications increased significantly in December-January. A sharp increase in appeals to national judicial and administrative authorities is recorded by several specialized organizations at once.
In the last two months alone, more than 30 administrative complaints have been filed with the Belgian State Council — these are appeals against the refusals of the country's Ministry of Finance to issue licenses for the withdrawal of blocked assets from Euroclear, the head of the service explained. Razmorozka.com Alexey Bogdanov. According to him, until recently it was about one or two such complaints in a few months, whereas now the process has actually been put on stream.
The growth in activity is also confirmed by other market participants. The number of complaints to the Belgian State Council has at least doubled compared to previous periods, said Konstantin Balabushko, founder of the Sky Bond Eurobond agency. Since the beginning of December, in principle, there has been an increase in the number of lawsuits to Belgian courts for blocked assets, added Irina Rotachkova, senior associate at the BGP Litigation Compliance and Sanctions Law Practice.
The reason for the surge is largely due to the abrupt change in the approach of the European authorities to dealing with the blocked assets of Russians. Starting in September 2025, the Belgian Ministry of Finance began to refuse investors en masse — the previous practice, which allowed individuals to successfully withdraw funds, was suddenly revised, explained Artem Kasumyan, senior associate at the Delcredere Bar Association. It was this change that prompted investors to appeal the regulator's decisions in court.
At the same time, the Belgian Treasury has already announced the suspension of the practice of refusing to issue licenses for unblocking after investors have filed complaints with the State Council, follows from the department's letter in response to the service's letter. Razmorozka.com . This means that the complaints have worked and the system will be reviewed.
Izvestia also sent a request to the Belgian Ministry of Finance.
Why are investors actively complaining about the decisions of the Belgian Ministry of Finance
The massive refusals of the Belgian Ministry of Finance on applications for unblocking assets in many cases look poorly justified and contradict EU law and established practice, said the head of the international service. Razmorozka.com Alexey Bogdanov. This means that such decisions can and should be challenged, as they do not stand up to legal scrutiny.
The quality of the arguments in the refusals of the Ministry of Finance is now extremely low, Konstantin Balabushko added. According to him, the decisions look like a template, have the same structure and actually reproduce the same legal position.
Since September 2025, the Belgian Ministry of Finance has also stopped taking into account the individual circumstances of applicants, said financial lawyer Olga Plekhanova. According to her, even EU citizens whose assets passed through the Russian infrastructure receive refusals.
The principle of protecting legitimate expectations applies in law: the authorities are obliged to apply the rules consistently, emphasized Artyom Kasumyan. The sharp tightening of practice by the Belgian Ministry of Finance contradicts this principle and has not been explained in any way.
Changing the position of the Belgian regulator may have a political motivation, Konstantin Balabushko believes. In 2025, the fate of Russian assets and the possibility of their withdrawal were discussed for a long time in the EU. Formally, it was about the reserves of the Central Bank of the Russian Federation, but the assets of private investors were also under uncertainty. In order to maintain control over them until a political decision was reached, the Ministry of Finance tightened checks and began using any formal reasons for refusals.
What is the way to unlock assets
Submitting an application to the Belgian Ministry of Finance is a mandatory starting point for unblocking assets, Konstantin Balabushko noted. If the investor still faces a refusal, he will be able to apply to the State Council and appeal the decision.
The withdrawal of assets through the permission of the Belgian regulator is the only really working option for defrosting blocked funds, said Evgenia Amelkina, director of the Eastern Legal Alliance. Nevertheless, the trial is quite expensive and lengthy. If the amount of blocked assets exceeds $100,000, it is definitely worth addressing the issue: in this case, the risk of losing money is higher than the cost of lawyers.
At the same time, each case is different, said financial lawyer Olga Plekhanova. There have been cases when an investor spent about 500 euros on self-filing an application and obtained a license when the Ministry of Finance had not yet applied for mass refusals. Such clients are currently at the stage of actual withdrawal of funds through Euroclear.
There are already real successful cases: clients who received licenses were able to withdraw assets to European accounts in 2025, Alexey Bogdanov noted. The fastest process took about 14 months, but after changing the regulator's approach, it is reasonable to set a timeframe of two to three years.
The first meetings of the State Council on December and January complaints will begin in February 2026, but decisions on the merits should be expected no earlier than 2028, the expert explained. At the same time, some cases are already close to the final, and under a favorable scenario, decisions in favor of investors may appear by May 2026, Konstantin Balabushko noted.
What to do for investors with small portfolios
There are hundreds of thousands of private investors in Russia with blocked assets, and the vast majority of them are individuals with small portfolios acquired before 2022, a Delcredere representative explained. For them, the judicial path in Belgium is often inaccessible.
For investors with small amounts locked up, it makes sense to participate in the exchange mechanisms that several large brokers offered in 2025, added Irina Rotachkova, senior associate at BGP Litigation. Investors are offered the transfer of shares and bonds blocked in Euroclear in exchange for the provision of Russian securities and funds from C-type accounts from non-residents.
By the end of 2025, four brokers — T-Investments, Investment Chamber, Kit Finance and BCS — announced the collection of applications for the exchange of foreign securities of Russians for Russian securities of non-residents. Investment companies undertake to obtain all necessary permits, while the conditions vary. In addition, Finam plans to start collecting applications in January.
In 2024, there was already a centralized exchange of blocked assets between Russians and foreigners, explained Natalia Milchakova, a leading analyst at Freedom Finance Global. At the first stage, foreign investors bought securities for 8.1 billion rubles out of the proposed 35 billion, at the second stage — for another 2.5 billion.
However, then investors managed to compensate on average about 25% of the amounts up to 100 thousand rubles, which is only a small fraction of the total amount of blocked assets of individuals.
Some investors preferred to wait for the improvement of the geopolitical situation and the unblocking of assets, but this should not be counted on, Natalia Milchakova notes. Even after the conflict ends, the EU links their return to the payment of "reparations" to Ukraine, which Russia will not agree to, she is sure.
— Now investors should use any available opportunities to obtain individual EU permission to withdraw funds through European courts, — the specialist emphasized.
It makes sense to defend your rights after a refusal, Artyom Kasumyan noted. Not appealing the decision means tacitly agreeing with it. With a large number of lawsuits and successful precedents in the State Council, investors have a chance to change the prevailing negative practices regarding Russian assets.
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