VERBA LEGAL obtained 3 licenses from the Belgian Treasury in one day for release of securities and funds of Russian private investors in Euroclear. The assets amounted to more than €60,000,000.

The VERBA LEGAL sanctions team believes that this is definitely a good sign: the process of obtaining licenses is picking up pace

However, we should not forget about the US and UK sanctions against the NSD. OFAC and OFSI general licenses are valid until 12 October 2024, which means that transactions with the NSD are allowed without obtaining individual licenses. After 12 October, final transfer of assets from Euroclear to a private investor's account will require an additional license from OFAC and/or OFSI. Under these conditions, investors are definitely taking advantage of the faster application processing by the Belgian Treasury.

At the same time, Euroclear is sceptical about the applicability of OFAC General License No. 99A to individual releases. VERBA LEGAL continues negotiations with the depository and still hopes for a positive outcome for its clients.

The project is pursued by lawyers of the Sanctions Law practice: Tatyana Neveeva (Senior Partner), Marat Samarsky (Counsel), Nikita Zhemchugov (Senior Lawyer), Yulia Koroleva (Junior Lawyer) and Tatyana Zelenovskaya (Junior Lawyer).