United States
Authority enactedREPO Act (2024) enables seizure and transfer. Not implemented by Biden; status under Trump administration unclear as peace negotiations continue. REPO 2.0 introduced Sept. 2025 to mandate implementation.
Russia's frozen sovereign assets:
background, legal framework,
and what's at stake.
A comprehensive briefing on the background, legal framework, key decisions, where jurisdictions stand, and what remains unresolved, for policymakers, journalists, academics, and researchers.
Central bank reserves, not oligarch wealth.
Russian sovereign assets are central-bank reserves and related state holdings: funds accumulated by the Russian government and held in foreign financial institutions. These are distinct from private Russian assets or oligarch wealth, which are subject to different legal rules and procedures.
Roughly €190 billion is held at Euroclear in Belgium. An additional €22 billion is held in France. The assets remain frozen but are not being used for reparations; current mechanisms generate approximately €3 billion annually in windfall profits, a fraction of what Ukraine needs.
Ukraine's total reconstruction needs are estimated at $588 billion and rising (World Bank, Feb. 2026). Even full repurposing of the frozen principal would not cover Ukraine's needs entirely, but it represents the single largest available source of reparations funding.
Distribution of frozen Russian state assets.
> €100B €10B – €100B €1B – €10B < €1B
Canada
C$140M
Estimate; not officially reported
France
~€22B
Japan
~$30B
Estimate; not officially reported
Switzerland
~€8B
United Kingdom
~£8B
Estimate; not officially reported
United States
~$5B+
Full amount in classified annex; not publicly reported
Belgium
~€190B
Held via Euroclear
Australia
A$9B
Estimate; not officially reported
Amounts shown reflect direct holdings in each jurisdiction: assets held by the Central Bank of Russia in accounts or securities at institutions in that country. They do not include assets held through correspondent accounts or indirect custodial arrangements, which may substantially increase effective exposure in some jurisdictions. For a full breakdown, see the detailed breakdown by jurisdiction.
Four pillars of the legal case.
A growing body of international-law scholarship and state practice supports using Russia's frozen sovereign assets for Ukraine. The case rests on four main legal foundations.
- 01
Reparations obligation
Under ARSIWA art. 31(1) and UNGA Resolution ES-11/5, Russia bears a binding legal obligation to compensate Ukraine for the destruction it has caused.
- 02
Lawful countermeasure
The freezing of Russian assets is a lawful countermeasure under the law of state responsibility. Third-party states may take countermeasures in response to serious violations of jus cogens norms.
- 03
Transfer vs. indefinite immobilisation
There is no material legal difference between holding assets indefinitely and transferring them outright. Both deprive Russia of access for the same duration and purpose; Russia cannot claim damages because it owes more than the frozen amount.
- 04
Historical precedent
Following Iraq's invasion of Kuwait (1990), the US, UK, and France transferred frozen Iraqi state assets to an international escrow account without Iraq's consent; the same framework: reparations obligation, claims commission, frozen assets as funding source.
The main objections do not withstand scrutiny.
Full objections & answers- Would transferring assets put Europe at war with Russia?
- No. Financial and economic measures are explicitly recognised as non-forcible countermeasures under international law. Transferring assets enforces Russia's existing legal obligation; it is not an act of war under Article 2(4) of the UN Charter.
- What about legal retaliation from Russia?
- Russia has filed suit before the EU’s General Court, timed to create legal uncertainty, not to win on the merits. Sovereign immunity does not apply to sanctions measures adopted by political institutions; the countermeasures doctrine favours the EU; the Court has repeatedly dismissed similar challenges.
- What about Russia seizing Western private assets?
- Russia is already doing this regardless: Fortum, Uniper, Carlsberg, and Danone have all had assets seized since 2023. Russia’s behaviour is not contingent on Western action on frozen state assets.
- What about financial-stability risks?
- A growing body of economic analysis argues that the precedent of allowing aggressor states to benefit financially from illegal wars poses a greater long-term threat to the international financial order than transfer does.
From the initial freeze to the current landscape.
- 2022
- Feb 2022G7 + EU
Initial immobilisation of Russian sovereign assets
Within days of Russia's full-scale invasion, G7 nations and the EU froze approximately $300 billion in Russian central-bank reserves, the largest concentration (~€190 billion) held at Euroclear in Belgium.
- Jun 2022Canada
Canada enacts asset-seizure authority
Canada became the first G7 country to legislate explicit authority to seize, forfeit, and redistribute sovereign assets under amendments to its Special Economic Measures Act.
- Nov 2022UN
UNGA Resolution ES-11/5: Russia must pay reparations
Adopted by 94 votes to 14, recognising Russia's legal obligation to pay reparations to Ukraine and calling for an international mechanism to register damages.
- 2023
- May 2023Council of Europe
Register of Damage for Ukraine established
An international body to document evidence and claims for damage caused by Russia's aggression, forming the evidentiary foundation for future reparations proceedings.
- 2024
- Feb 2024EU
EU windfall-profits mechanism established
The European Council required Euroclear and other depositories to segregate windfall profits; close to €5 billion was directed to Ukraine across 2024–25.
- Apr 2024US
REPO Act signed into law
President Biden signed the REPO Act, authorising the executive to seize Russian sovereign assets and transfer them to Ukraine. Not implemented before Biden left office.
- Oct 2024G7
G7 finalises $50 billion ERA loan
The Extraordinary Revenue Acceleration loan: $50 billion to Ukraine serviced by future windfall profits from frozen Russian assets over ten years.
- 2025
- 9 Jul 2025ECtHR
ECtHR holds Russia responsible for human-rights violations in Ukraine
The Grand Chamber unanimously held Russia responsible for widespread and systematic violations in eastern Ukraine since 2014.
- 3 Dec 2025EU
European Commission proposes Reparations Loan
The Commission proposed using ~€210 billion in frozen Russian cash balances as the basis for a €90 billion loan, repayable only if Russia pays reparations. Shelved in favour of EU market borrowing.
- 12 Dec 2025EU
EU enacts indefinite-immobilisation legislation
The Council enacted legislation under Article 122 TFEU indefinitely immobilising Russian state assets until Russia ends its war and pays reparations, removing any Member State's individual veto power.
- 16 Dec 2025Council of Europe
International Claims Commission Convention signed
The EU and 35 countries signed the Convention establishing the International Claims Commission for Ukraine. Enters into force after 25 ratifications.
- 18 Dec 2025EU
EUCO agrees €90 billion loan; Reparations Loan shelved
EU leaders agreed to a €90 billion loan through 2027 based on EU market borrowing. The Commission was tasked with continuing work on the Reparations Loan. No decision on the principal.
- 2026
- Mar 2026Canada
Canada's Bill C-15 receives Royal Assent
Including Division 18 amendments to SEMA requiring federal financial institutions to report on sanctioned property and profits in their possession.
- Mar 2026EU General Court
Russia's Central Bank files suit before EU's General Court
Targeting the December 2025 indefinite-immobilisation regulation. For analysis of why the case is unlikely to succeed, see Addressing the Objections.
- 07 May 2026Canada
Canadian Bill S-214 passes committee
Bill S-214 to amend the Special Economic Measures Act (repurposing of foreign state assets) passes committee and moves to third reading.
The principal remains untouched.
No decision has been made on the use of the ~€210 billion in frozen principal in the EU, nor the remaining amounts in other jurisdictions. The €90 billion loan addresses Ukraine's immediate funding needs through 2027, but the windfall-profits mechanism generates only approximately €3 billion annually, insufficient to meet reconstruction needs or provide meaningful accountability.
The political and legislative landscape.
European Union
Partial measuresLargest holder (~€200B at Euroclear). Windfall profits in use; ERA loan operational; indefinite immobilisation enacted. Principal untouched; Reparations Loan under development.
United Kingdom
Active debatePublicly supportive. Exploring specific legal tools; seeking alignment with G7 and EU rather than acting unilaterally.
Canada
Authority enactedFirst to legislate seizure (2022). Bill C-15 (2026) expanded SEMA powers; Bill S-214 currently at third reading moves from authority toward implementation.
Japan
Active debateSecond-largest holder after Europe. Supports Ukraine but wary of financial-system implications. Open to collective G7 decisions.
Others
Active debateAustralia, Switzerland, and others engaged in legal and political debates. No decisive action beyond initial freezes.
Concrete steps available now.
Several interim steps are available to policymakers that would move toward resolution without requiring full agreement on outright transfer. Neither segregation nor moving assets to a trust alters ownership, so neither raises issues of seizure or confiscation.
- 01
Segregate the assets
Use prudential regulatory powers to transfer Russian assets and liabilities into a purpose-built entity managed by a consortium of willing EU governments, reducing systemic risk to Euroclear while preserving the freeze.
- 02
Establish a compensation trust
Move assets out of Euroclear and into a multinational compensation fund using EU Treaty powers already invoked for indefinite immobilisation: Articles 122(1), 212, and 215 TFEU.
- 03
Ratify the Claims Commission
The Council of Europe Convention establishing the International Claims Commission needs 25 ratifications to enter into force. Each ratification brings the formal compensation mechanism closer to operation.