§ LegislationReference
Sanctions and asset-related legislation
A consolidated reference to the laws, regulations, and executive instruments that freeze, segregate, and authorize the use of Russian sovereign assets across G7 jurisdictions.
Jurisdiction
European Union — Immobilization of Russian state assets
4 instrumentsThe legal instruments that established the EU’s Russia sanctions framework and froze Central Bank reserves within EU jurisdiction.
Established the EU's Russia sanctions framework in response to the destabilization of Ukraine. Required unanimous renewal every six months.
Implemented the EU's Russia sanctions framework. Because it depended on Council Decision 2014/512/CFSP, it effectively had to be renewed every six months as well.
Added Article 5a(4) to Regulation 833/2014, prohibiting management of the Central Bank of Russia's reserves. This effectively immobilized roughly €210 billion held in the EU.
Established an indefinite prohibition on returning the state assets, ending reliance on repeated sanctions renewals. Requires a qualified majority to change or repeal.
Unlike Canada and Australia, the relevant entities are not formally designated. Instead, the model is similar to the US and UK: the law prohibits transfer of the assets without designating the entities.
Article 2 — Prohibition on transfer1. Any direct or indirect transfer of assets or reserves of the Central Bank of Russia, or of any legal person, entity or body acting on behalf of, or at the direction of, the Central Bank of Russia, such as the Russian National Wealth Fund, shall be prohibited.
2. Cash balances corresponding to the assets and reserves referred to in paragraph 1 shall be managed separately.
European Union — Segregation of frozen assets & use of profits
3 instrumentsThe framework requiring central securities depositories (CSDs) like Euroclear to segregate frozen state assets, account for extraordinary revenues, and contribute net profits to support Ukraine.
Introduced the first legal obligations on central securities depositories (CSDs). CSDs holding more than €1 million of Russian Central Bank assets were required to:
- Keep the extraordinary cash balances separate
- Account separately for resulting revenues and net profits
- Not dispose of the resulting net profits
This was the first step towards capturing the windfall profits generated by frozen assets.
Established that extraordinary profits earned by CSDs on frozen state assets after 15 February 2024 would become subject to a future contribution to Ukraine.
This effectively allowed CSDs to keep all extraordinary profits earned prior to this date. For Euroclear, this amounted to approximately €5.2 billion in profits retained.
Adopted the political decision that extraordinary net profits earned by CSDs on frozen state assets should be made available to support Ukraine. Required CSDs holding more than €1 million of Russian Central Bank assets to:
- Make financial contributions equal to 99.7% of after-tax profits
- Temporarily retain up to 10% for prudential purposes (legal defense and similar costs), with anything left over eventually made available for Ukraine
Contributions are made to the Union budget but earmarked for Ukraine. After the ERA Loan program was created, these funds would be paid by the Union budget to the Ukraine Loan Cooperation Mechanism (ULCM), which services the EU's Macro-Financial Assistance Loan and the ERA loans of other nations.
European Union — Extraordinary Revenue Acceleration (ERA) loans
1 instrumentAdopted 24 October, entered into force 29 October 2024. This regulation:
- Established the Ukraine Loan Cooperation Mechanism (ULCM)
- Created the Macro-Financial Assistance Loan (the EU's ERA Loan to Ukraine)
- Provides exceptional macro-financial assistance to Ukraine
The ULCM services both the MFA Loan and the ERA loans made to Ukraine by other G7 partners. In theory, revenue earned on frozen assets across the G7 should be paid into the ULCM.
It remains unclear whether anyone outside the EU is paying into the ULCM. It appears that almost all funds servicing the MFA Loan and ERA loans are coming from Euroclear.
European Union — €90 billion Ukraine support loan (2026–2027)
3 instrumentsA three-part legislative package establishing a major loan facility with an explicit right to use frozen Russian assets for repayment.
Established the €90 billion loan facility (Ukraine Support Loan for 2026–2027). Passed by qualified majority. In case of nonpayment, the Union reserves its right to use the immobilized Russian assets for repayment.
Recital (13)On the same date, 25 Member States agreed that the loan should be repaid by Ukraine only once reparations are received. Until then, the assets of the Central Bank of Russia should remain immobilised and the Union should reserve its right to make use of them to repay the loan, in full accordance with Union and international law.
Recital (49)In line with the firm support of 25 Heads of State and Government in the margins of the European Council of 18 December 2025, the Ukraine Support Loan should be repaid by Ukraine once reparations from Russia are received, and the Union reserves its right to make use of the Russian assets immobilised in the Union to repay the loan, in full accordance with Union and international law.
Article 20(2)(n) — Operative clauseThe Union has the right to make use of Russian assets immobilised in the Union to repay the loan, in full accordance with Union and international law.
Article 20 governs the contents of the Ukraine Support Loan Agreement. Paragraph (2) lists the mandatory terms that must be included. Sub-paragraph (n) is the legally operative clause requiring the Agreement to include a contractual term recognizing the Union's right to resort to the immobilized Russian assets, subject to Union and international law.
Amendment to the Ukraine Facility Regulation. Allowed the loan proceeds to be channelled through the Ukraine Facility. Passed by qualified majority.
Amendment to the Multiannual Financial Framework (MFF). This was the final act in the three-part package:
- Extended the EU-budget guarantee ("headroom")
- Created the Ukraine Support Loan Instrument to cover debt-service costs on the borrowing
- Required unanimity to pass (unlike the other two acts, which only needed qualified majority)
Adopted after Hungary lifted its veto.
European Union — Reparations loan to Ukraine
1 proposalProposal for a Regulation establishing the Reparations Loan to Ukraine and amending Regulation (EU) 2024/792 (Ukraine Facility).
- The draft regulation was proposed but never enacted
- It remains a live Commission proposal (COM document) that only requires qualified majority to be adopted
- Legislative procedure: 2025/3502(COD) — Ordinary legislative procedure (ex-codecision)
- Current status: Awaiting Parliament's position in 1st reading
Canada
4 instrumentsCanada has both designated the relevant Russian state entities and enacted seizure authority, and is now considering reforms to strengthen enforcement.
The Regulations (SOR/2014-58) were amended on this date to designate the following entities under Part 2 of Schedule 1:
- Central Bank of the Russian Federation
- National Wealth Fund of the Russian Federation
- Ministry of Finance of the Russian Federation
Because they are listed in Schedule 1, they are subject to section 3 of the Regulations, which prevents dealing with their assets.
Unlike the US, UK, and EU (which prohibit transactions without designating entities), Canada directly lists the entities, subjecting their assets to a dealing prohibition.
SEMA (S.C. 1992, c. 17) was amended on this date to allow the seizure of state assets. Under Section 4(1), the Governor in Council may:
- (a) Make orders or regulations restricting or prohibiting activities in relation to a foreign state
- (b) Cause to be seized or restrained any property situated in Canada that is owned or held or controlled, directly or indirectly, by a foreign state or identified person
These powers may be exercised when any of the following circumstances exist:
- An international organization has called on members to take economic measures
- A grave breach of international peace and security has occurred
- Gross and systematic human rights violations have been committed
- A foreign public official is responsible for significant acts of corruption
S.C. 2026, c. 3. The definition of "foreign property" in Part 2, Section 13 (Obligations Specific to Financial Institutions) allows and requires Canada to look through account holders, such as Euroclear, to identify who they are holding money for.
Definition — "Foreign property""Foreign property means any property that is situated in Canada and that is owned — or is held or controlled, directly or indirectly — by a person, including a foreign state, that is identified in an order or regulation made under subsection 4(1)."
An Act to amend the Special Economic Measures Act (disposal of foreign state assets). The date marks when it passed its third reading in the Canadian Senate. It must now go to the House of Commons.
- Private members bill originally sponsored by former Senator Ratna Omidvar, now sponsored by Senator Donna Dasko
- Seeks to remove courts from the seizure process to avoid issues of sovereign immunity preventing SEMA from functioning as intended when used to seize state assets
United States
4 instrumentsThe US uses executive authority under IEEPA and OFAC directives to immobilize Russian sovereign assets, and has enacted legislation authorizing their seizure and transfer.
50 U.S.C. §§ 1701–1710. The primary statute granting the President authority to regulate or prohibit transactions involving foreign property after declaring a national emergency.
IEEPA itself does not identify Russia or freeze any particular assets. It provides the legal authority for the President to do so via executive order and OFAC directives.
Issued under IEEPA. This executive order:
- Authorizes sanctions against persons and entities connected with Russia's harmful foreign activities
- Provides the legal basis for later directives targeting Russian sovereign financial institutions
OFAC prohibits U.S. persons from engaging in any transaction involving:
- The Central Bank of the Russian Federation
- The National Wealth Fund of the Russian Federation
- The Ministry of Finance of the Russian Federation
Unlike Canada and Australia, the US has not designated these entities. Instead, like the EU and UK, it prohibits transactions involving them. The U.S. Treasury stated this action "effectively immobilizes any assets of the Central Bank of the Russian Federation held in the United States or by U.S. persons, wherever located."
Rebuilding Economic Prosperity and Opportunity for Ukrainians Act. Allows the President to seize, confiscate, transfer, or vest any Russian aggressor state sovereign assets subject to U.S. jurisdiction, for the purpose of transferring those funds to the Ukraine Support Fund.
Funds in the Ukraine Support Fund may be used for:
- (A) Making contributions to an international body, fund, or mechanism for compensation or assistance to Ukraine
- (B) Supporting reconstruction, rebuilding, and recovery efforts in Ukraine
- (C) Providing economic and humanitarian assistance to the people of Ukraine
United Kingdom
2 instrumentsThe UK prohibits financial services to Russian state entities rather than formally designating them, similar to the US and EU approach.
Creates the UK's independent sanctions framework after Brexit. Empowers ministers to make regulations imposing financial sanctions, including asset freezes, against states, entities, and individuals for purposes including national security and compliance with international obligations.
Regulation 18A was added to the Russia (Sanctions) (EU Exit) Regulations 2019 on this date. It is the provision that immobilizes Russian state assets in the UK.
Unlike Canada and Australia, the UK has not designated the Central Bank, the National Wealth Fund, or the Ministry of Finance. Instead, like the US and the EU, it prohibits persons from engaging in transactions involving these entities. UK financial sanctions apply to all persons within the territory and territorial sea of the UK, and to all UK persons wherever they are in the world, including legal persons established under UK law and their branches.
Regulation 18A — Prohibition on financial services(1) A person ("P") must not provide financial services to a person mentioned in paragraph (2) where (a) the financial services are for the purpose of foreign exchange reserve and asset management; and (b) P knows, or has reasonable cause to suspect, that the financial services are provided to such a person.
(2) The persons mentioned in this paragraph are:
(a) the Central Bank of the Russian Federation,
(b) the National Wealth Fund of the Russian Federation,
(c) the Ministry of Finance of the Russian Federation,
(d) a person owned or controlled directly or indirectly by a person mentioned in (a) to (c), or
(e) a person acting on behalf of or at the direction of a person mentioned in (a) to (c).(4) A person who contravenes the prohibition in paragraph (1) commits an offence.
Australia
Legislation for this jurisdiction is being compiled and will be added shortly.
Switzerland
Legislation for this jurisdiction is being compiled and will be added shortly.
Japan
Legislation for this jurisdiction is being compiled and will be added shortly.