BELGIUM Trends and Developments Contributed by: Valerijus Ostrovskis, Coline Cauvin, Yapa Thepkanjana and Delphine Buyle, ACQUIS
ACQUIS Rue du Trône 98 1050 Brussels Belgium
Tel: +32 0 2 887 94 10 Email: info@acquislp.eu Web: www.acquislp.eu
Introduction As the EU sanctions regime against Russia enters its fifth year, the issues arising in Belgian practice are increasingly those of a mature framework. Alongside the adoption of new measures, practitioners are now spending more time on the administration of exist - ing restrictions, on enforcement, and on the growing body of litigation that the measures have generated. Belgium occupies a particular position in this regard, as host to the EU institutions and to Euroclear, the central securities depository in which the large major - ity of immobilised Russian assets are held. The reach of EU restrictive measures has also contin - ued to widen beyond Russia and Belarus. The past year has seen: • the reactivation of the United Nations sanctions against Iran through the snapback mechanism, alongside the continued development of the EU’s own Iran-related measures; • the build-out of newer thematic regimes, includ - ing the framework targeting Russia’s destabilising activities abroad and the regime addressing hybrid threats; and • in the opposite direction, a substantial easing of the measures concerning Syria. Economic security has emerged as a prominent theme alongside sanctions, reflected in the revision of the foreign direct investment screening framework and the first serious consideration of the Anti-Coercion Instrument in early 2026. Although these measures are taken at the EU level, they shape the work of Belgian operators and advisers, who must absorb an expand - ing and increasingly varied body of restrictions.
Euroclear and the Immobilised Russian Assets Euroclear, the Brussels-based central securities depository, has been at the heart of EU financial sanc - tions since 2022, as the institution holding the bulk of the immobilised assets of the Central Bank of Russia. It holds approximately EUR200 billion of such assets, which places Belgium at the centre of the debate over their future use. The reinvested balances continue to generate substantial income, the greater part of which is transferred to the Union as an exceptional contri - bution in support of Ukraine under the framework adopted in 2024. On 12 December 2025, acting on the basis of Article 122 of the Treaty on the Functioning of the European Union, the European Council (the “Council”) immobi - lised the assets on an indefinite basis, replacing the previous arrangement under which the freeze required renewal every six months by unanimity. The change was designed to prevent a single member state from securing the release of the assets by declining to sup - port a renewal, and it places the freeze on a more durable footing than before. The Belgian position on the measure was nuanced: while Prime Minister De Wever publicly questioned the legal basis for invoking Article 122, in the absence, in his view, of the econom - ic emergency that provision presupposes, Belgium ultimately supported the indefinite immobilisation, its principal concerns being directed at the separate proposal to use the assets to fund a reparations loan. At its meeting of 18 and 19 December 2025, the Council did not adopt the proposed reparations loan and instead agreed to provide Ukraine with a loan of EUR90 billion for 2026 and 2027, funded by EU bor - rowing on the capital markets. Belgium had sought
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