Russia’s central bank and several Russian billionaires have launched legal actions to recover their frozen assets in Europe.
If the challenges succeed, European Union countries could face multibillion-euro payouts and a direct clash between national investment treaties and EU law.
The cases target Belgium in particular because most of the blocked Russian sovereign assets — around €185 billion — are at Brussels-based securities depository, Euroclear.
If successful, Moscow-linked businessmen and Russian authorities could recover amounts approaching the €60 billion they are seeking in pending claims.
Brussels lawyer Tibère Devis said the situation is already legally tense. “If there’s a conflict between national rules and EU law, EU law wins,” he told Brussels Signal yesterday .
“It’s these investment treaties that could end up being declared illegal. And many procedures are now pending.”
Those treaties, signed decades ago when European States were courting Soviet investment, allow private investors to sue governments when assets are seized.
“Those who were not personally sanctioned but still saw their assets frozen had a real chance of getting their money back,” Devis said.
He said that creates a structural clash with EU sanctions rules, which sit higher in the legal hierarchy. That is why Russia-linked investors are testing them in court while national treasuries refuse to release even the assets of non-sanctioned Russian citizens.
“Except now, the treasury refuses even in cases where it’s a simple Russian citizen. So many procedures are pending …. Primacy of EU law over domestic law,” Devis added.
Russia’s central bank has already taken Euroclear to an arbitration court in Moscow, accusing the clearing house of “illegal actions” and demanding that its funds be returned. Euroclear said it could not yet react to the move this morning, according to Belgian newspaper Le Soir.
Oligarchs and companies close to the Kremlin are using the same legal route. According to the Veblen Institute for Economic Reforms, a non-profit think-tank, at least 24 known cases now directly challenge EU or Ukrainian sanctions. Claims already total $62 billion (€52.8 billion) and several involve frozen funds held specifically at Euroclear.
Some suits hit other capitals. Luxembourg is being sued by one sanctioned oligarch for $16 billion (€13.6 billion). France faces a €3.8 billion claim from Alexey Mordashov over a blocked mining project in French Guiana, and another case from Samvel Karapetyan after the seizure of property on the Côte d’Azur.
Belgium fears Euroclear is being singled out while other countries avoid sharing the exposure. Prime Minister Bart De Wever has warned of retaliation and legal action if the EU forces the institution to support financing plans for Ukraine using the frozen funds.
France is also watching the situation closely. Its commercial banks hold around €18 billion of Russian central bank funds.
Paris refuses to disclose which institutions are involved, citing confidentiality rules and contractual obligations to pay interest on the deposits — unlike Euroclear, which treats the accrued interest as a “windfall”.
Meanwhile, EU countries agreed yesterday to immobilise indefinitely Russian sovereign assets, clearing a major obstacle to a planned €210 billion “reparations loan” for Ukraine.
They backed a revised use of Article 122 of the EU Treaty, allowing decisions without unanimity. Euroclear confirmed that ambassadors had “agreed on a revised version of the Article 122 proposal” with a “very clear majority” and launched a written procedure for final approval.
The move is meant to prevent more Russia-friendly EU governments from unfreezing the money simply by opposing sanctions renewal every six months. It also blocks Moscow’s hopes of recovering the assets as part of a future settlement — an idea supported by US President Donald Trump but rejected in Europe.
The EU says returning the funds would destabilise the bloc’s economy and could trigger new Russian hybrid attacks.
Devis said the legal conflict may now go “very far”, since dozens of arbitration cases are running in parallel.
What is already clear is that Russia and its investors are using many tool available — and most of the money remains at Euroclear, placing Belgium and the EU at the centre of a legal fight.
