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- Priceless securities: new stages of exchange of blocked assets are being discussed in Russia
Priceless securities: new stages of exchange of blocked assets are being discussed in Russia
The authorities are working on options for returning assets blocked abroad to Russians, Deputy Finance Minister Ivan Chebeskov told Izvestia. He said that European and American investors are interested in this, but Western regulators are hindering this process. Now there are three possible directions: new asset exchanges, the use of blocked funds of non-residents in Russia and individual licenses from Western regulators, lawyers say. What obstacles arise and what investors themselves can do now — in the Izvestia material.
What are the options for unblocking Russian assets?
The authorities are discussing initiatives to exchange blocked assets, but now it has to be done precisely and carefully, because in the West they are trying to counteract any such idea, Deputy Finance Minister Ivan Chebeskov told Izvestia. According to him, European and American investors themselves are interested in the exchange. But Western regulators, for political purposes, are trying to block even those initiatives that are of interest to their citizens.
— We are looking at giving businesses and citizens the opportunity to receive blocked funds. And a number of such initiatives have already worked," he stressed.
The mechanism for the exchange of blocked assets was developed back in 2023. The President signed a decree according to which the foreign securities of Russians frozen in the accounts of the National Settlement Depository (NSD) in the European depositories Euroclear and Clearstream were allowed to be exchanged for assets of foreigners blocked in the Russian Federation, which are stored in special accounts of type "C".
The first stage of the exchange was completed in August 2024. Then foreign investors bought assets worth 8.1 billion rubles. This is about a quarter of the amount of applications submitted by citizens of the Russian Federation (35.3 billion rubles). Russians could only apply for an exchange of securities worth no more than 100 thousand rubles per person. At the first stage, 708 thousand retail investors partially received their funds back.
The second stage was launched on September 3, 2024, but the total amount exchanged was even lower. At the end of March 2025, Euroclear Bank had €195 billion worth of frozen Russian assets (about 18 trillion rubles). At the same time, according to the latest data, foreign investors had about 500 billion rubles in accounts of type "C", the senior partner of the Pen bar association recalled & Paper by Anton Imennov.
Today, the Russian authorities have limited room for maneuver, the founder of the service believes Razmorozka.com Alexey Bogdanov. Theoretically, there are three directions: new asset exchanges, the use of blocked funds of non-residents in Russia, and individual licenses from Western regulators. However, each of these mechanisms faces serious limitations, he warned.
Why there are no new exchange stages yet
In the first scenario with a mass exchange, the main difficulty is that a foreign investor who has bought the blocked assets of a Russian investor does not automatically receive the opportunity to dispose of them. For subsequent unblocking, he still needs the permission of the Western regulator. And he still sees the paper historically associated with NSD and the sanctions infrastructure. That is, the mechanism does not actually solve the problem for Western investors, explained Alexey Bogdanov. For the EU, these operations may look like indirect economic benefits to the Russian financial system, which contradicts the basic logic of the sanctions regime.
A full-fledged exchange mechanism will require either amendments to EU sanctions regulations or a special decision at the European Union level that explicitly authorizes such transactions and sets the conditions for their implementation, the expert emphasized.
The previous exchange deals were mainly made possible due to the fact that the EU and Belgium's position was not finalized at the start of the first stage, explained Anton Imennov from Pen. & Paper. But then the European Commission explicitly banned participation in such a scheme due to the sanctions status of NSD.
He added that brokers also offered separate options for unblocking frozen assets, but their capabilities are objectively limited. They cannot unlock assets in Euroclear or Clearstream on their own. In other words, the problem remains the same — the lack of a legal mechanism on the EU side. Therefore, the most realistic scenario for mass exchange is an attempt to find a political solution, the expert believes.
The situation may change either with the appearance of a scheme excluding the participation of sanctioned persons, or in the case of broader political agreements between Russia and Western countries, Anton Imennov agreed. However, the latter, in his opinion, is unlikely to happen soon.
Nevertheless, if a warming of relations does occur, asset exchange transactions will begin to be launched, says Andrey Sirotkin, senior lecturer at the Department of Banking at Synergy University. Izvestia has sent a request for the willingness of foreign regulators to exchange to the Belgian Ministry of Finance, the ECB and the US Treasury.
Another scenario is also possible, in which the exchange will be resolved on an individual basis with the participation of large international investors, says Irina Rotachkova, senior associate at the BGP Litigation Compliance and Sanctions Law Practice.
Earlier, another idea was being worked out — "voluntary-forced asset exchange." Its essence actually lies in the use of funds in "C" type accounts, Natalia Milchakova, a leading analyst at Freedom Global, recalled. In her opinion, this option would be the easiest for Russians.
Should Russian investors sue for asset recovery
So far, the way that can really work is individual permits, says financial lawyer Olga Plekhanova. Their logic is clear to the European regulator: a specific investor, a separate package of assets, a confirmed ownership right, and the goal of removing securities from the sanctions chain.
That is, individual licenses from Western regulators remain one of the main opportunities for private Russian investors. Most often — from the Ministry of Finance of Belgium. This path is not fast and requires a significant amount of documents, but the mechanism is already working. According to the Belgian Ministry of Finance, in 2024, 446 appeals were considered and permits for defrosting were issued in 186 cases, Olga Plekhanova added.
— Now we have initiated dozens of cases in the Belgian court, — said Alexey Bogdanov from the service Razmorozka.com .
He explained: if the regulator unreasonably delays the consideration of the application or issues a refusal, violating legal principles, then the court proceedings may force the administration to re-examine the case and correct violations.
The licensing procedure remains the most relevant for Russian investors, says Artem Kasumyan, Senior Associate at Delcredere. According to him, it has its own risks of refusal to unlock, it requires foreign passports or residence permits, as well as accounts. Nevertheless, there is currently no adequate alternative to this procedure.
There is a pause in the work of the Belgian regulator today, Irina Rotachkova from BGP Litigation noted. However, the resumption of issuing permits is expected in the fall of 2026.
Now many people are also winning lawsuits against Euroclear in the Moscow Arbitration Court, said Olga Plekhanova, a financial lawyer. Last year, investors began actively filing lawsuits against the Belgian depository for unblocking their foreign accounts, Izvestia previously reported. This makes it possible to recover unpaid coupons, dividends, and bond repayment amounts, Irina Rotachkova said. However, the securities themselves are not being received yet. There are still no real prospects for the execution of such court decisions, including due to the prohibition of debit from accounts of type "C".
Rather, a positive decision by the Russian court may help the affected investor in the future, said Natalia Milchakova, a leading analyst at Freedom Global. For example, if there is a political agreement to unlock assets, then Euroclear in the future will probably primarily satisfy the demands of those who filed a lawsuit in advance.
Individual work with a license from the Belgian Ministry of Finance and potential judicial support is most often economically justified for amounts starting from several hundred thousand euros. Otherwise, the cost of legal support may not be comparable to the expected result. But when submitting an application on your own, it may be advisable to apply from several tens of thousands of dollars, Olga Plekhanova noted.
For large investors, such a strategy may make sense, but it must be understood that it will be a difficult path with ambiguous results, said Svetlana Frumina, Head of the Department of Global Financial Markets and Fintech at Plekhanov Russian University of Economics.
According to Irina Rotachkova, it is economically feasible to go to court with investment portfolios starting from 1 million rubles (approximately $10-15 thousand). With smaller amounts, it will often be more expedient to sell assets at a discount on the over-the-counter market or continue to hold them in the account until the situation is resolved.
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