Euroclear: the opaque vault at the heart of Europe

On 17 July 2026, a Russian appeals court upheld a ruling ordering Euroclear to pay more than 18 trillion roubles, over €200 billion, to the Central Bank of Russia. The judgment is unenforceable outside Russia, and the Brussels depository does not recognise the court’s jurisdiction. But it captures the essence of the moment: Europe’s largest securities infrastructure, a house the general public has never heard of, has become the epicentre of a €200 billion legal, financial and geopolitical standoff. To inaugurate our European coverage, a deep dive into a vault whose opacity is not an accident but an architecture.

A quarter of a century ago, a book about a Luxembourg securities depository triggered one of the longest judicial sagas in the history of the French press. In 2026, no investigation is needed to find out where the frozen reserves of the Central Bank of Russia sleep: they sit in Brussels, at Euroclear, their amount is disclosed in quarterly press releases, and their fate keeps foreign ministries busy. Yesterday’s secret is now published at press conferences, without having lost any of its explosive charge.

Forty-four trillion under custody

Start with the scale, because it conditions everything else. Euroclear is not a bank in the everyday sense: it is a central securities depository (CSD), the layer of the financial system where bonds, equities and funds are registered, safekept and delivered against payment. At the end of March 2026, the group held close to €44 trillion in assets under custody for its clients, and the value of transactions settled in its books reached €1,390 trillion over the year 2025, roughly twelve times world GDP. When a Dutch pension fund buys a French government bond or a Japanese bank delivers a eurobond, odds are the trade settles inside this machine.

History explains the geography. Euroclear was born in Brussels in 1968, inside the local branch of the American bank Morgan Guaranty, to settle eurobonds, those securities issued outside any national jurisdiction, whose market was then exploding. Two years later, rival banks created Cedel in Luxembourg, which would become Clearstream. The two houses, competitors to this day, share the same function and the same discretion: they are international central securities depositories (ICSDs), the crossroads of the global bond market. Their regulation has thickened considerably since, with the European CSD Regulation of 2014 (Regulation (EU) 909/2014) and, for Euroclear Bank, supervision by the National Bank of Belgium. An infrastructure of this size does not live in a regulatory grey zone. Its opacity lies elsewhere.

Opacity by design

The central mechanism is the omnibus account. A depository like Euroclear does not open accounts for savers or companies: its clients are banks and custodians, which pool the securities of their own clients into collective accounts. Each link in the chain knows only the adjacent link. Euroclear sees the custodian bank, the bank sees the asset manager, the manager sees the fund, and the final beneficiary appears nowhere in the books at the top. This nesting-doll arrangement was not designed to hide anything: it mutualises costs, enables netting, and makes it possible to settle hundreds of thousands of transactions a day. Without omnibus accounts, there is no global bond market at this price point.

The trade-off is structural: economic ownership becomes invisible to the very infrastructure that safekeeps it. Hence the entire complexity of the Russian file. Of the roughly €210 billion of Central Bank of Russia assets immobilised in the EU, the bulk is lodged at Euroclear: €183 billion at the end of 2024 according to the group’s own accounts, an amount that moved above €200 billion in the first quarter of 2026 as securities matured and turned into cash. Untangling what belongs to the central bank, to sanctioned entities or to ordinary non-sanctioned Russian investors means climbing back up custody chains that the system was never designed to expose.

Révélation$, the archaeology of suspicion

This architecture has a polemical history, and it is as French as it is Luxembourgish. In February 2001, journalist Denis Robert and former Cedel executive Ernest Backes published Révélation$, an investigation accusing Clearstream, Euroclear’s Luxembourg rival, of having maintained a system of unpublished accounts that could serve tax evasion and money-laundering circuits. A decade of defamation trials followed, dozens of proceedings, and finally, on 3 February 2011, three rulings by the French Court of Cassation vindicated the journalist in the name of the public-interest debate and the seriousness of his investigation, on the basis of Article 10 of the European Convention on Human Rights.

Two points of fairness are in order. First, the so-called Clearstream 2 affair, the fake account listings used to smear French political figures, has nothing to do with the original documentary work: it durably blurred the public perception of the case. Second, Euroclear is not Clearstream, and nothing in the 2001 investigation targeted the Brussels house. If we summon this history, it is for a precise reason: the mechanism questioned at the time, chains of accounts that no regulator or journalist could unwind end to end, is the same one that today makes the Russian assets both possible to immobilise and so hard to seize cleanly. In twenty-five years, the question has simply changed hands: it is no longer put by a journalist to an infrastructure, but by states to their own financial system.

The 2022 freeze, an accidental rent

On 28 February 2022, four days after the invasion of Ukraine, the European Union prohibited all transactions with the Central Bank of Russia. The reserves Moscow had parked in European securities, mostly safekept at Euroclear, were immobilised: neither confiscated nor returned. Then market mechanics did their work. Bonds matured, coupons fell due, and all that cash piled up in the books of Euroclear Bank, which redeposited it with central banks. At the end of March 2026, Euroclear Bank’s balance sheet stood at €237 billion, of which €200 billion related to sanctioned Russian assets. A settlement infrastructure found itself, despite itself, with a balance sheet that is six-sevenths Russian.

That cash earns money. Interest on the Russian assets reached €4.4 billion in 2023, €6.9 billion in 2024, then €5 billion in 2025, down 26% as rates eased, and another €2.3 billion in the first half of 2026. In total, about €17 billion of interest between 2022 and 2025, which along the way generated more than €4 billion in tax for the Belgian state.

Europe organised the capture of this rent without touching the principal. In February 2024, the Council required depositories to ring-fence these extraordinary revenues; in May 2024, the Council earmarked most of them for Ukraine, under the name of windfall contribution. Euroclear paid a first instalment of €1.5 billion in late July 2024, then €1.6 billion in July 2025, with a further €1.4 billion announced for 2026, bringing the total to €6.6 billion. These flows also service the $50 billion loan extended by the G7 in June 2024, the ERA, collateralised on the future revenues of the immobilised assets. The legal boundary is constantly restated by the institutions: under the European reading, the interest belongs to no one, while the principal remains Russian. On this ridge line, Europe is financing a war with the proceeds of a freeze, without ever uttering the word confiscation.

The reparations loan, chronicle of a deadlock

In the autumn of 2025, the Commission decided to change scale. Its idea, the reparations loan: mobilise not the interest but the cash balances themselves, lending them to Ukraine through a structure in which Kyiv repays only if Russia one day pays war reparations. The proposal formalised in December 2025 amounts to €165 billion of new support, €115 billion for defence and €50 billion for Ukraine’s budget, plus €45 billion to repay the G7’s ERA, for a total of €210 billion mobilised. Seven member states, from Finland to Poland, signed a letter of support, while the Commission, which also tabled a classic joint-borrowing option, openly pushed the asset-backed loan.

The blockage came from the host country. Belgian Prime Minister Bart De Wever demanded political, legal and financial guarantees: were the freeze ever lifted, or were Russia to win an arbitration, Belgium and Euroclear would face a €200 billion claim alone. The Commission proposed a system of national guarantees distributed by gross national income, but several capitals balked, and the commitments remained, in Brussels-the-Belgian’s eyes, insufficiently binding. At the same moment, the 28-point American peace plan of November 2025 crashed into the scheme: it envisaged investing $100 billion of frozen Russian assets in a reconstruction vehicle led by Washington, with half the profits going to the United States, the remainder feeding a joint US-Russian investment vehicle. For the Europeans, who discovered the text without having been consulted, it was confirmation that their main negotiating lever could slip from their hands.

The European Council of 18 December 2025 produced a scaled-back compromise: €90 billion of support for 2026-2027, financed by EU borrowing backed by the headroom of the European budget, with no recourse to the Russian assets. The text, backed by 25 heads of state and government, accommodates Czechia, Hungary and Slovakia through enhanced cooperation, explicitly reserves the right to use the Russian assets to repay the loan, and asks that technical and legal work on the reparations loan continue. A week earlier, a quieter move had locked the mechanism in place: on 12 December, the Council adopted Regulation 2025/2600, based on Article 122 of the Treaty, prohibiting any transfer of Central Bank of Russia assets back to Moscow and making contrary Russian judgments unenforceable in the Union. The immobilisation, until then hostage to the unanimous renewal of sanctions every six months, became de facto indefinite, and adopted by qualified majority. Some jurists see a bold innovation, others a bypass of the common foreign policy’s own rules; both readings can be true at once. The framework of the €90 billion loan was settled by the Council on 4 February 2026, finalised on 23 April, and the June summit endorsed a first disbursement before the end of June 2026.

The war of the courts

The Russian response unfolded on every front at once, and 2026 turned it into a judicial war of attrition. In December 2025, the Central Bank of Russia filed a claim before a Moscow arbitration court to recover its assets, and announced it would seek damages from European lenders. On 27 February 2026, it challenged the immobilisation regulation before the General Court of the European Union, invoking the sovereign immunity of its assets and the contestable choice of qualified-majority voting. On 15 May, the Moscow court ordered Euroclear to pay more than 18 trillion roubles in damages, around $250 billion. Euroclear, which faces more than a hundred proceedings in Russia, does not recognise the court’s jurisdiction and counter-attacked on 30 June before the Brussels enterprise court, asking a European judge to declare the Russian claim groundless. On 17 July, the Russian judiciary rejected Euroclear’s appeal and upheld the ruling.

None of these Russian judgments is enforceable in Europe, and Regulation 2025/2600 was written precisely so that they never become so. Their function lies elsewhere: to build a legal claim that can be executed against Western assets still present in Russia, where the holdings of Euroclear clients trapped in type-C accounts run into the billions, and to weigh on any future peace negotiation. Each side is methodically manufacturing its own legal reality, in mirror image. The outcome will most likely be decided neither in Moscow nor in Brussels, but by the balance of power that determines which of the two legal orders applies to the other side’s assets.

The precedent and the currency

There remains the question that goes beyond Euroclear: what is a reserve currency worth if its assets can be withheld indefinitely by political decision? The European Central Bank has held a consistent line: no lender-of-last-resort role in any structure resembling monetary financing, which the treaties prohibit, and a demand for legal clarity that Christine Lagarde repeated as late as her press conference of 18 December 2025, since confidence in the euro is also played out on this ground. The Commission itself long rejected outright confiscation, on the grounds that it would violate sovereign immunity and expose the Union to retaliation. The underlying argument is familiar: if reserves held in euros become seizable, third-country central banks, from Beijing to Riyadh, will reallocate part of their holdings towards gold, whose record accumulation by central banks we have documented, or towards jurisdictions perceived as neutral. The de-dollarisation debate has shown how slow and often overstated such shifts are; it has also shown that they accelerate precisely after shocks to confidence.

The most concrete risk is nonetheless more prosaic, and it lives in the plumbing. Euroclear is a systemic counterparty: a CET1 capital ratio of around 57% in the first quarter of 2026 makes it one of the best-capitalised institutions in Europe, but its balance sheet remains 85% immobilised Russian assets. Confiscating the principal would turn a depository position, neutral by construction, into a €200 billion debt to a hostile creditor, with a precedent invocable against any central bank client. The group itself has publicly warned the Union about the consequences of using the assets: loss of confidence among international investors, cascading litigation, and the weakening of an infrastructure on which the settlement of European debt depends, the same collateral plumbing whose mechanics and breaking points we have described on the American side.

Overblown risks? The case made by the loan’s supporters

Fairness requires laying out the opposite reading, championed by part of Europe’s economists and lawyers. For the Centre for European Reform, the legal risks of the reparations loan are largely ill-founded: Russia has already lost the Uniper v. Gazprom arbitration in 2024 and Krymenergo v. Russia in 2025, it refuses to appear before the very fora it invokes, and the December 2025 regulation neutralises the enforcement of its judgments inside the Union. Liquidity buffers exist, the authors add: force majeure clauses, regulatory grace periods, and, as a last resort, emergency liquidity assistance from central banks. Christine Lagarde herself judged the latest version of the scheme legally more solid than its predecessors, a notable shift in the ECB’s position. As for the precedent for the euro, the loan’s supporters point out that the freeze has lasted four years without any measurable flight of official reserves out of the euro area, and that the alternative, making the European taxpayer pay rather than the aggressor, creates a risk of its own, a political one.

This debate is not settled, and our editorial protocol requires saying so: nobody has a solid empirical basis for quantifying the effect of a confiscation on the euro’s reserve status, because the event would be unprecedented at this scale. Both camps reason in scenarios, not in data.

Three paths for a vault

As we publish, three paths remain open, and these are scenarios, not forecasts. The first is the rentier status quo: indefinite immobilisation keeps producing a few billion in interest a year, shrinking as rates fall, which Europe captures without touching the principal. This is the default trajectory, the one set by Regulation 2025/2600 and the €90 billion loan. The second is the revival of the reparations loan: the December conclusions demand in black and white that technical and legal work on the instrument continue, and the file will return if Ukraine’s needs overflow the 2026-2027 envelope or if the guarantees demanded by Belgium are finally assembled. The third is a negotiated settlement of the conflict in which the assets become a bargaining chip, along the lines sketched by the American plan of November 2025; paradoxically, this would be the most destabilising scenario for Europe, which would watch the lever change hands.

The signals to watch are identifiable: Euroclear’s quarterly results, which every three months photograph the Russian balance sheet and the rent; the EU General Court’s ruling on the Central Bank of Russia’s challenge, the first judicial test of the immobilisation regulation; the Brussels proceedings opened on 30 June; and every European Council, where the question of financing Ukraine beyond 2027 will mechanically return. An infrastructure designed for the shadows now spends its quarters in the spotlight, with a European regulation written for it, a $250 billion Russian judgment bearing its name and foreign ministries tracking its cash balances release after release. Twenty-five years after Révélation$, nobody is searching for the money anymore: it is located to the nearest billion, in public quarterly reports. The fight is now over who gets the right to use it.

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Primary sources: Euroclear, results press releases for 2023, 2024, 2025 and Q1 2026, and the update on Russian sanctioned assets (May 2026); Council of the EU: ring-fencing of extraordinary revenues (12 February 2024), earmarking of net profits for Ukraine (21 May 2024), Regulation (EU) 2025/2600 of 12 December 2025, European Council conclusions of 18 December 2025, position of 4 February and finalisation of 23 April 2026 of the €90 billion loan, European Council of 18-19 June 2026; European Commission: two financing options (December 2025), first transfer of €1.5 billion (July 2024), €1.4 billion transfer (2026); ECB, press conference of 18 December 2025; European Parliament, EPRS briefing “Financing Ukraine in 2026 and 2027”; Regulation (EU) 909/2014 (CSDR), EUR-Lex.

Analysis: Centre for European Reform (Tordoir and Paduano, 18 December 2025); CEPR VoxEU; Just Security; Institut Jacques Delors; Lawfare.

Press: La Libre (17 July 2026) and 15 May 2026; L’Avenir (30 June 2026); RTBF; The Moscow Times (16 May 2026) and 18 December 2025; Euronews (3 March 2026) and 21 November 2025; Axios, full text of the 28-point plan; Euractiv. On the history of the Clearstream affair: Wikipedia and Ouvertures.net on the Court of Cassation rulings of 3 February 2011 (in French). Figures and dates checked against the sources cited; rouble and dollar amounts are orders of magnitude converted at current rates.