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 instruments
The 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 transfer
1. 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 cash reserves created by sanctions & use of profits
3 instruments
The framework requiring central securities depositories (CSDs) like Euroclear to segregate "cash balances accumulating exclusively due to restrictive measures" on Russian state assets, account for extraordinary revenues, and contribute net profits to support Ukraine.
Note: Sanctions produced an unintended consequence: central securities depositories (CSDs) and banks accumulated extraordinarily large cash reserves. This occurred because Russia had instructed these institutions to invest in bonds on its behalf. As those bonds matured, they converted into cash, and under normal circumstances, Russia would then withdraw the corresponding amount. Sanctions, however, prevent Russia from making such withdrawals, so the cash remains with the CSDs and banks, which hold legal ownership of it.
Because these institutions may need to repay Russia on short notice once sanctions lift, they keep this cash liquid rather than committing it to long-term investments. In practice, they reinvest it overnight on a continuing basis so that it remains readily accessible. This ongoing reinvestment generates profits that exist only because sanctions created these unusual cash reserves in the first place. For this reason, these earnings are called extraordinary profits, extraordinary revenues, or windfall profits.
The press commonly refers to these accumulated reserves as "frozen Russian assets," but this characterization is misleading. The cash itself belongs to the CSDs and banks, not to Russia, as do the profits earned from managing it. Russia's actual claim is narrower: once sanctions end, it holds the right to be repaid the value it is owed.
This distinction explains why EU regulations avoid the term "frozen Russian assets," referring instead to "cash balances accumulating exclusively due to the restrictive measures" or "cash balances corresponding to the assets and reserves." These regulations govern how CSDs manage their own cash reserves, reserves that exist solely because of sanctions, along with the income those reserves generate.
Introduced the first legal obligations on central securities depositories (CSDs) holding more than €1 million of Russian Central Bank assets. They 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 extraordinary cash balances as a result of sanctions on the frozen Russian assets.
Established that windfall profits earned by CSDs after 15 February 2024 on "cash balances accumulating exclusively due to the restrictive measures" 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 to make available for Ukraine's support the extraordinary net profits that CSDs earn on cash reserves accumulated as a result of sanctions. 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 instrument
Note: G7 members agreed to lend Ukraine a total of $50 billion across various currencies. The regulation below establishes the mechanism for gradually repaying these ERA loans using the extraordinary profits generated by sanctions-created cash reserves in the EU.
Adopted 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 instruments
A 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 immobilized 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 immobilized in the Union to repay the loan, in full accordance with Union and international law.
Article 20(2)(n) — Operative clause
The Union has the right to make use of Russian assets immobilized 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.
Canada 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. Amended SEMA: 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. Also created a mechanism analogous to the EU for the segregation and utilisation of windfall profits.
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
The 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.
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 instruments
The 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 directly designates Russian state entities under its autonomous sanctions framework. While Australian law freezes designated assets, it currently provides no mechanism for the unilateral seizure of sovereign assets.
The enabling statute for Australia's autonomous (non-UN) sanctions regime. Part 2, Division 1 deals with the power to impose sanctions. The operative provision is Section 10, which authorizes regulations providing for:
Proscription of persons or entities
Restriction or prevention of uses of, dealings with, and making available of, assets
Restriction or prevention of the supply, sale, or transfer of goods or services
Restriction or prevention of the procurement of goods or services
Indemnities for acting in compliance with the regulations
Compensation for owners of assets affected by asset restrictions
The date reflects the latest consolidated version of the Act.
The regulations that give operative effect to the Autonomous Sanctions Act. The key provisions for Russian state assets are:
Regulation 6, Item 6A sets out the criteria for designating Russian persons and entities. The Minister may designate a person or entity that is, or has been, engaging in activity of economic or strategic significance to Russia, as well as current or former senior Russian government officials and their immediate family members.
Regulation 14 prohibits directly or indirectly making an asset available to, or for the benefit of, a designated person or entity (unless authorized by a permit under Reg 18).
Regulation 15 is the operative freezing provision. It prohibits a person who holds a controlled asset from using or dealing with the asset, allowing it to be used or dealt with, or facilitating its use, unless authorized by a permit under Reg 18.
A "controlled asset" is defined in Regulation 3 as an asset owned or controlled by a designated person or entity.
Regulation 15 — Prohibition of dealing with controlled assets
(1) A person contravenes this regulation if: (a) the person holds a controlled asset; and (b) the person: (i) uses or deals with the asset; or (ii) allows the asset to be used or dealt with; or (iii) facilitates the use of the asset or dealing with the asset; and (c) the use or dealing is not authorised by a permit granted under regulation 18.
While Russian state assets can be frozen under this framework, Australian sanctions legislation currently provides no mechanism for the unilateral seizure of those assets. The closest related mechanism is proceeds of crime legislation, which requires a judgment of criminality by a court. DFAT told the Senate committee that "under Australian sanctions law, there is no power to do anything with those assets other than to have them frozen."
The date reflects the latest consolidated version of the Regulations.
Schedule 2, Part 2 (Designated entities) sets out the list of designated entities for the purposes of the Autonomous Sanctions Regulations. The following Russian state entities are designated:
Central Bank of Russia (item 10)
National Wealth Fund of the Russian Federation (item 23)
Ministry of Finance of the Russian Federation (item 24)
Russian Direct Investment Fund (item 7)
Bank for Development and Foreign Economic Affairs / Vnesheconombank (item 17)
Australia's approach is similar to Canada's: it directly designates the relevant entities, unlike the US, UK, and EU, which prohibit transactions involving these entities without formally designating them.
Note — AUD-denominated assets and the question of Euroclear holdings in Australia
A significant amount of Russian central bank funds may be connected to the Australian financial system. Euroclear has consistently reported that 2% of its Russia sanctions-related cash balances are denominated in Australian dollars. That 2% equates to approximately A$7 billion (roughly US$5 billion).
Before 2022, the Central Bank of Russia held investments in Australian dollars, including government bonds, and Euroclear acted as custodian of these securities. Payments from Australian bonds may therefore have accumulated in Australian bank accounts held by Euroclear.
However, DFAT estimates total frozen Russian assets in Australia (state and private combined) at "well less than $100 million". This discrepancy suggests Australia does not currently treat Euroclear-held funds as frozen Russian property. As a result, those assets could potentially be withdrawn if EU sanctions were to lapse.
The August 2026 Senate committee report raised this gap directly and recommended that the Australian government clarify how much Euroclear holds in Australia, whether any of those funds derive from CBR investments, and what arrangements are in place to ensure that Euroclear cannot use assets it holds in Australia to discharge its financial obligations to the CBR.
The date reflects the latest consolidated version of the List.
The committee's report identifies shortcomings in Australia's sanctions regime, including gaps in scale, enforcement, and alignment with allies. On frozen assets, the report raises the question of Euroclear's AUD-denominated holdings (paras 2.24–2.36), noting DFAT's estimate of less than A$100 million in frozen Russian assets while Euroclear reports approximately A$7 billion in AUD-denominated Russia sanctions-related cash balances. The committee found that Australia does not appear to treat these Euroclear-held funds as frozen Russian property, creating a risk that the assets could be withdrawn if EU sanctions lapsed. The report recommends that the Australian government consider legislation to seize Russian sanctioned entity assets and disburse them to Ukraine, and that financing Russia's military operations be made a criminal offence with forfeiture of assets as a penalty.