BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Coline Cauvin, Delphine Buyle and Yapa Thepkanjana, ACQUIS
Belgium at the Centre: Euroclear and Immobilised Russian Assets Euroclear, the Brussels-based central securities depository, holds approximately EUR200 billion of Russian central bank assets immobilised in the EU. That concentration placed Belgium at the heart of a heated debate in late 2025 over the Commission’s proposal to use those assets to finance Ukraine. The Belgian government held firm, demanding full mutu - alisation of the legal and financial risks and legally binding guarantees from all member states before agreeing. The reparations loan ultimately collapsed. EU lead - ers agreed at the December 2025 summit to raise EUR90 billion on capital markets to support Ukraine in 2026–2027, stepping back from direct use of the
third states, and horizontal sanctions regimes targeting violations of human rights, terrorism, and cyber and hybrid threats; and • generally applicable sectoral sanctions prohibiting certain transactions with counterparts from sanc - tioned jurisdictions, or involving sanctioned sec - tors, goods or entities. As regards Russia, Belgium does not maintain an autonomous sanctions regime. It applies and enforces the restrictive measures adopted at EU level. These include individual restrictive measures against natural and legal persons, entities and bodies, including asset freezes and prohibitions on making funds or economic resources available to listed parties. The EU framework also includes sectoral and eco - nomic measures, including restrictions relating to finance, trade, energy, transport, technology, defence, and the provision of certain professional and business services. 1.4.2 Scope of Sanctions Public authorities, financial institutions, corporations and private individuals within this scope must apply EU sanctions. Generally, EU sanctions apply broadly to all individu - als or entities within the territory of the EU. They have a wide reach and also apply: • on board any aircraft or any vessel flying or sailing under the flag of an EU member state; • to EU nationals, regardless of where they are located; • to any person or entity conducting business, even in part, within the EU; and • to entities incorporated under the law of an EU member state, wherever they operate. While the EU formally maintains that its sanctions do not have extraterritorial application, recent regula - tory developments have introduced obligations that produce extraterritorial effects in practice. In par - ticular, the EU has adopted a combination of obliga - tions imposed on EU operators that affect conduct and relationships outside the EU, anti-circumvention
immobilised assets. 1.3 Key Industries
With Belgium being the institutional centre of the EU, its jurisdiction has numerous sectors that are strongly affected by sanctions regulations. These include:
• financial services; • the energy sector; • defence and dual-use goods; • technology and telecommunications; • international trade; • maritime and shipping; • luxury goods and diamonds; and • healthcare and pharmaceuticals.
Belgium was particularly affected by the financial sanctions, owing to the presence of world-leading securities depository Euroclear. The EU’s maximum oil price and ports ban affected the North Sea ports. The EU diamond ban affected the Antwerp diamond industry hub. 1.4 Overview 1.4.1 Types of Sanctions Belgium supports and implements UN- and G7-agreed sanctions, as well as EU autonomous sanctions. Broadly speaking, these include: • sanctions against individuals, such as asset freez - es, travel bans under restrictive measures against
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