Unlocking foreign assets
With our European partners, we provide full legal support for the process of unlocking assets of Russian investors by obtaining an individual license from the EUROCLEAR / CLEARSTEAM regulator, aimed at:

  • Transfer of securities from the Russian depository system to an unsanctioned European broker (in accordance with the requirements of the EU Regulation, within the EU or in Switzerland), with the possibility of submitting a license to sell securities after their withdrawal from the NSD account to the European broker
  • Transfer of coupon payments of Russian investors to the European depository system

Individual approach
An individual approach to each specific situation, searching for optimal solutions and developing a strategy based on the client’s request and real circumstances.

  • Analysis of clients’ documents, information on the asset structure in order to determine the prospects for unlocking assets
  • Checking the client for inclusion in the lists of sanctions, checking for the presence of PEP status, checking the due diligence and indisputable ownership of assets
  • Coordination with the international regulator of a personalized package of documents attached to the application for a license
  • Preparation of documents for submission to the Belgian Treasury and/or the Ministry of Finance of Luxembourg
  • Selection of a guarantor (a European legal entity) for unlocking the foreign securities
  • Monitoring the consideration of the client’s application for a license
  • Working with the NSD, broker, client in order to complete the assets unlocking procedure upon receipt of a personal license

What is also possible:

  • Obtaining an OFAC license to unlock assets connected to US jurisdiction
  • Appealing the refusal to issue a license to higher authorized bodies in Belgium and/or Luxembourg
  • Assistance in opening a current account and/or brokerage account in the EU or Switzerland
  • Assistance in obtaining a residence permit/permanent residence permit in Europe

Additional information
Formal requirements for license issuing:

  • Availability of a European guarantor for the investor (a special legal entity registered in the EU, authorized to conduct compliance) for unlocking securities
  • Absence of the investor in the sanctions lists, absence of PEP status, absence of other sanctioned participants in the asset storage (except NSD)
  • Collective application for unlocking from the broker, submitted before 07.01.2023
  • Termination of the broker’s legal relationship with NSD

Informal requirements (increasing the chance of a positive consideration of the application for a license):

  • Availability of an account with a European broker for keeping the unblocked funds in accordance with the EU Regulation
  • Availability of a temporary residence permit/permanent residence permit or citizenship of another country for opening a brokerage account to which the unlocked assets will be transferred
  • Residence or center of vital interests in the EU
Obtaining an individual license for assets unlocking is a labor-intensive process. It requires attention and knowledge of the intricacies of this procedure. Our team has sufficient experience that let us provide you with full support for the successful completion of this procedure. We even can prepare an application for a license in Flemish, which will further increase the chances of receiving a positive decision from the international regulator.
Our company closely cooperates with qualified individuals who have acted as guarantors on repeated occasions. Recognized experts in their field are ready to help you with returning your assets.

We provide support to:
Russian investors who have blocked assets in the form of securities and income on them, funds from their redemption in the international depositories Euroclear and/or Clearstream, both with and without:

  • European citizenship
  • Residence permit/permanent residence in Europe
  • Current account and/or brokerage account in a European bank
  • Please note that for the pre-trial settlement of a dispute arising from the requirement of unlocking assets, there is a preclusion period expiring in March 2025, before the expiration of which investors should take measures to protect their rights.
Practice professionals
  • Anatoly Popenko

Contact Us
Volkhonka str. 6, Moscow, Russia, 119019
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