EU Sanctions Intensify: What Investors Should Expect with Frozen Assets in Euroclear

24

05.25

The European Union continues to expand its sanctions pressure in response to ongoing geopolitical tensions. In 2025, the EU adopted its 17th sanctions package, which includes:

  • Additional restrictions on Russian financial and infrastructure institutions;

  • New individual sanctions targeting specific persons and entities;

  • Enhanced oversight to prevent circumvention of sanctions via third countries and affiliated structures;

  • A ban on providing certain financial and investment services to Russian residents.

Against this backdrop, the process of unfreezing assets held in Euroclear is becoming increasingly complex and legally uncertain. Although the core legal framework—most notably EU Regulation No. 269/2014—remains unchanged, the Belgian Ministry of Finance, which implements these rules, has significantly tightened its administrative approach.

Applicants must now submit a highly detailed and well-substantiated documentation package that demonstrates:

  • The investor’s good faith;

  • A complete lack of direct or indirect ties to the National Settlement Depository (NSD);

  • Compliance with updated administrative requirements.

Key Changes in the Practice of the Belgian Ministry of Finance:

 

  • A noticeable increase in the formalization of application reviews;

  • Rejections are increasingly issued using standardized, generic language without case-specific analysis;

  • Tougher requirements for the guarantee letter from an EU guarantor—now expected to include not only transactional support but also liability for the applicant’s actions;

  • An increasing number of denials must be challenged before the Belgian Council of State, requiring strong legal arguments and procedural knowledge.

Stricter Compliance Checks by European Brokers

 

Even if an investor successfully unfreezes assets in Euroclear, they often face a second obstacle: many EU-based brokerage firms now refuse to accept such assets without extensive compliance verification.

Current market practices include:

  • Requiring an official license or regulatory authorization from the national financial authority where the broker is domiciled, permitting the reception of previously frozen assets;

  • Scrutinizing not only the origin of funds, but also the entire history of security ownership;

  • Imposing internal restrictions on clients whose assets were previously linked to NSD, even if those clients are not on any sanctions list.

This practice, widely referred to as “overcompliance”, reflects an excessive application of sanctions rules by private entities seeking to mitigate their own legal and reputational risks.

How DTK Partners Can Assist

 

DTK Partners offers comprehensive legal support at all stages of the asset unfreezing process, including:

  • Preparing and submitting applications to the Belgian Ministry of Finance for the unfreezing of Euroclear assets;

  • Challenging refusals before the Belgian Council of State;

  • Communicating with EU-based brokers and preparing compliant documentation, including assistance in obtaining regulatory approvals.

We closely monitor EU sanctions legislation, track the evolving administrative practice in Belgium, and develop tailored legal strategies to protect our clients’ interests.

📩 Contact us today — we will assess your case, propose a legal strategy, and guide you through the complex unfreezing process in full compliance with current EU requirements.