Commentary from Tatyana Neveeva, Managing Partner, and Nikita Zhemchugov, Senior Lawyer, for Pravo.ru

Many Russians have their assets frozen due to Western sanctions: they can no longer use them, but still must pay for their maintenance. Holders have a chance to get their property released by going through a complex bureaucratic quest. It is important to fill out the application correctly and set up an active dialogue with the foreign regulator, experts say. You need not only to prove the legality of the asset, but also to describe its further transfer to another jurisdiction. See the expert advice on assets release in the material.

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[...] To apply for release, you need to collect a package of documents. These can be divided into groups: personal documents, documents with the current and future broker (if release of securities is concerned), said Tatyana Neveeva, Managing Partner of VERBA LEGAL

Personal documents include a residence permit and any evidence of staying at a new place, for example, rental agreements, utility bills. Brokerage documents must confirm the legality of the asset and the transactions. These include a brokerage agreement, an account statement, evidence of termination of the relationship with the broker, new account details. If any other assets (accounts or real estate) are concerned, you must similarly prove the legality of their acquisition and explain how the assets will be removed or sold. Trustee’s documents must be submitted as well. 

“The purpose of submitting documents is to confirm the connection with the location, prove the legality of the purchase of the asset and guarantee its further transfer to a foreign jurisdiction,” Tatyana noted.

[...] When applying for release, you must indicate an account in a foreign bank. The frozen assets will be transferred to it later. In the EU, you are allowed to transfer property to banks with European registration only, Nikita Zhemchugov said. 

"You should bear in mind that opening an account in a European bank is not easy, even if you have a European residence permit: banks will definitely ask you to confirm your source of income outside of Russia and request other information," Nikita Zhemchugov noted.

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