Frozen Russian Sovereign Assets

After Russia's full-scale invasion of Ukraine in February 2022, the G7, EU, Australia, and other partners immobilised roughly USD 300 billion in reserves belonging to the Central Bank of the Russian Federation (CBR). The bulk of these assets — commonly cited at around EUR 200 billion — sits in the European Union, predominantly at the Belgian central securities depository Euroclear. Smaller tranches are held in the United Kingdom, France, Germany, Switzerland, Japan, the United States, and Canada.

"Frozen" (or immobilised) is a narrower status than confiscated: legal title remains with the CBR, but the assets cannot be moved, sold, or used. This distinction matters because outright confiscation of a foreign state's central-bank reserves would test the customary international-law doctrine of sovereign immunity from execution, reflected in the 2004 UN Convention on Jurisdictional Immunities of States and Their Property.

Western governments have so far chosen intermediate measures:

• Windfall profits mechanism (EU, 2024): Council Regulation amendments require Euroclear to channel extraordinary revenues generated by the immobilised CBR assets to support Ukraine, with the first tranches transferred in July 2024.
• ERA Loans (G7, 2024): At the June 2024 Apulia summit, G7 leaders agreed an "Extraordinary Revenue Acceleration" loan of about USD 50 billion for Ukraine, to be repaid from the future income stream on the frozen assets.
• REPO Act (United States, April 2024): Authorises the President to seize Russian sovereign assets under US jurisdiction and transfer them to a Ukraine reconstruction fund, though US-held volumes are comparatively small.

Debate continues over full confiscation. Proponents (notably the UK, Canada, and several Baltic and Nordic states) argue it is justified as a countermeasure against Russia's breach of the jus cogens prohibition on aggression. Opponents, including the European Central Bank and France, warn it could undermine the euro's reserve-currency status, trigger Russian retaliation against Western assets, and set a precedent exploitable by other states.