SOCIETY
How EU Sanctions Have Ensnarled the Assets of Ordinary Russians
November 21, 2025
- Anna KuleshovaSociologist, Social Foresight Group
Some 3.5 million Russian citizens, including those who left Russia and have residency or citizenship abroad, have lost access to their invested capital because of sanctions, even though their assets have nothing to do with the state or oligarchs. Sociologist Anna Kuleshova looked at the issue in a special report.
This interview was originally published in Republic. We are publishing an abridged version here with their permission.
Mauro Sbicego / Unsplash
The assets of more than 3.5 million Russian citizens who owned shares in Western companies have been frozen under EU sanctions. This is the focus of a report titled “Collateral Freeze: How EU Sanctions on Russian Financial Infrastructure Captured Unsanctioned Private Capital” (Russian here, English here), written by sociologist Anna Kuleshova and Zhanna Nemtsova, cofounder of the Boris Nemtsov Foundation for Freedom and the Social Foresight Group.
The total number of clients of Russian brokers with frozen assets is 233,475 individuals. The total amount of the frozen assets is RUB 80.9 billion (less than EUR 1 billion). More than 80% of affected clients owned shares worth less than $1,350. Only 1.1% held assets worth more than $40,000.
Why are you publishing this well-reasoned rebuke of European bureaucracy now? I ask because, following the creation of the Platform for Dialogue between PACE and “Russian democratic forces in exile,” members of the Russian Antiwar Committee have become more vocal about the need to restore the ability of Russian capital to get out of Russia if anyone truly wants to influence Putin. Is this a coincidence or are you working in coordination?
Our research is not at all about enabling capital to leave Russia, though it is interesting that you interpreted it that way. That said, I cannot help but agree that capital flight would likely weaken the regime – this is a rather obvious idea. The report concerns foreign securities frozen in the EU that belong to non-sanctioned individuals.
You use data from the Russian Central Bank in your analysis. How did you ensure its reliability? It is no secret Russian government agencies are not known for transparency. Or does the quality of this data not affect your conclusions?
The study does not rely on any single source. We compared multiple datasets and tried to approximate the most reliable picture possible, fully aware of the limitations associated with each source.
As part of the study, an official request was sent to the Belgian Treasury and to the depositories Euroclear and Clearstream, asking for data on the size of the blocked assets and a breakdown of their composition. These are the main institutions where the money belonging to Russians, not connected to the government or oligarchs, is “stuck.” “The request went unanswered, which confirms the general problem of data opacity on the part of European depositories and regulators,” you write. On whose behalf was the request submitted? And are these institutions obligated under Belgian law to respond to such a request?
The request was submitted by Zhanna Nemtsova. The Treasury is a government body. In the EU, there is a right to request public information (access to documents). Euroclear and Clearstream are private global depositories, not state entities, and they are not obliged to disclose information to third parties who are not their clients or regulators. In that sense, the lack of a response is legally fine. However, the overall lack of transparency surrounding this issue is hard to ignore.
Are they obligated to respond to media inquiries if the questions are asked by local journalists? Will you seek allies among local journalists or members of parliament who could submit a parliamentary inquiry that would be more likely to be answered?
A journalistic inquiry is unlikely to compel Euroclear or Clearstream to disclose figures, but a parliamentary inquiry is a more powerful tool, and it is indeed used in similar situations. We are working with journalists from the Luxemburger Wort daily and with members of the European Parliament from Luxembourg on this issue.
Am I correct in understanding that there is essentially no functioning process for obtaining asset-release licenses? Does your analysis provide evidence for simplifying these procedures?
A formal process exists, but it does not actually work. And yes, the analysis does provide arguments for improving it, as it reveals the discrepancy between the design of the mechanism and its real-world operation. Without a functioning process, the freeze becomes a permanent block rather than a temporary measure, the principle of proportionality in sanctions is violated and the EU financial system’s reputation for predictability and rule of law suffers.
Aggregated data shows that the vast majority of blocked assets belong to ordinary private investors who are not subject to sanctions. These individuals are not supposed to be the target of sanctions pressure at all. This allows for a public and legal argument that placing restrictions on such individuals is pointless and is not in line with the goals of sanctions policy.
Our report demonstrates that the unblocking mechanism is not working on any meaningful scale, lacks transparent regulatory standards and violates the principle of legal certainty. This gives grounds for appeals to the European Commission and national regulators, for inquiries from parliamentarians and for media coverage.
Did you find out from your interlocutors how much it cost them to unblock the assets, in terms of time and legal fees?
There are known cases that have dragged on for a year and a half or more, without resolution, still marked as “under review.” The real time frame ranges from 6 months to infinity. It sounds strange, but this is exactly how lawyers describe it: the regulator may just never respond. In complicated cases involving disputed documents or inheritance, legal costs can reach EUR 40,000-60,000. For a “simple” private investor with a EUR 10,000-100,000 portfolio, that makes no sense economically.
In this sense, is it even worth focusing on the size of the frozen funds? After all, it comes out to about EUR 12,000 per person.
No, focusing on the amount of damage is pointless – that is exactly what our research shows. The problem is not the amount but the principles, mechanisms and legal logic involved. The size of losses should not negate the possibility of the process itself.
The total number of clients of Russian brokers with frozen assets is 233,475 individuals. The total amount of the frozen assets is RUB 80.9 billion (less than EUR 1 billion). More than 80% of affected clients owned shares worth less than $1,350. Only 1.1% held assets worth more than $40,000.
Why are you publishing this well-reasoned rebuke of European bureaucracy now? I ask because, following the creation of the Platform for Dialogue between PACE and “Russian democratic forces in exile,” members of the Russian Antiwar Committee have become more vocal about the need to restore the ability of Russian capital to get out of Russia if anyone truly wants to influence Putin. Is this a coincidence or are you working in coordination?
Our research is not at all about enabling capital to leave Russia, though it is interesting that you interpreted it that way. That said, I cannot help but agree that capital flight would likely weaken the regime – this is a rather obvious idea. The report concerns foreign securities frozen in the EU that belong to non-sanctioned individuals.
You use data from the Russian Central Bank in your analysis. How did you ensure its reliability? It is no secret Russian government agencies are not known for transparency. Or does the quality of this data not affect your conclusions?
The study does not rely on any single source. We compared multiple datasets and tried to approximate the most reliable picture possible, fully aware of the limitations associated with each source.
As part of the study, an official request was sent to the Belgian Treasury and to the depositories Euroclear and Clearstream, asking for data on the size of the blocked assets and a breakdown of their composition. These are the main institutions where the money belonging to Russians, not connected to the government or oligarchs, is “stuck.” “The request went unanswered, which confirms the general problem of data opacity on the part of European depositories and regulators,” you write. On whose behalf was the request submitted? And are these institutions obligated under Belgian law to respond to such a request?
The request was submitted by Zhanna Nemtsova. The Treasury is a government body. In the EU, there is a right to request public information (access to documents). Euroclear and Clearstream are private global depositories, not state entities, and they are not obliged to disclose information to third parties who are not their clients or regulators. In that sense, the lack of a response is legally fine. However, the overall lack of transparency surrounding this issue is hard to ignore.
Are they obligated to respond to media inquiries if the questions are asked by local journalists? Will you seek allies among local journalists or members of parliament who could submit a parliamentary inquiry that would be more likely to be answered?
A journalistic inquiry is unlikely to compel Euroclear or Clearstream to disclose figures, but a parliamentary inquiry is a more powerful tool, and it is indeed used in similar situations. We are working with journalists from the Luxemburger Wort daily and with members of the European Parliament from Luxembourg on this issue.
Am I correct in understanding that there is essentially no functioning process for obtaining asset-release licenses? Does your analysis provide evidence for simplifying these procedures?
A formal process exists, but it does not actually work. And yes, the analysis does provide arguments for improving it, as it reveals the discrepancy between the design of the mechanism and its real-world operation. Without a functioning process, the freeze becomes a permanent block rather than a temporary measure, the principle of proportionality in sanctions is violated and the EU financial system’s reputation for predictability and rule of law suffers.
Aggregated data shows that the vast majority of blocked assets belong to ordinary private investors who are not subject to sanctions. These individuals are not supposed to be the target of sanctions pressure at all. This allows for a public and legal argument that placing restrictions on such individuals is pointless and is not in line with the goals of sanctions policy.
Our report demonstrates that the unblocking mechanism is not working on any meaningful scale, lacks transparent regulatory standards and violates the principle of legal certainty. This gives grounds for appeals to the European Commission and national regulators, for inquiries from parliamentarians and for media coverage.
Did you find out from your interlocutors how much it cost them to unblock the assets, in terms of time and legal fees?
There are known cases that have dragged on for a year and a half or more, without resolution, still marked as “under review.” The real time frame ranges from 6 months to infinity. It sounds strange, but this is exactly how lawyers describe it: the regulator may just never respond. In complicated cases involving disputed documents or inheritance, legal costs can reach EUR 40,000-60,000. For a “simple” private investor with a EUR 10,000-100,000 portfolio, that makes no sense economically.
In this sense, is it even worth focusing on the size of the frozen funds? After all, it comes out to about EUR 12,000 per person.
No, focusing on the amount of damage is pointless – that is exactly what our research shows. The problem is not the amount but the principles, mechanisms and legal logic involved. The size of losses should not negate the possibility of the process itself.
Vardan Papikyan / Unsplash
You write that assets were frozen, including those of pensioners. This is a striking detail that is meant to evoke an emotional response from the reader. But you do not specify the percentage of this group. How many pensioners are among those who lost access to their savings? And where do they live, according to your geographic breakdown?
According to brokers, those over 60 make up 6.4% of all affected clients; in our survey, those over 60 constitute 5.2%. Brokers’ data does not allow us to determine where these individuals live. Our data includes a distribution by type of settlement (municipality), but this group is still relatively small within the survey. In the report, we noted that the survey reflects the most active and affluent segment of the affected population.
It is important to emphasize that, statistically, there could certainly be pensioners among the investors. Investing is accessible to a broad segment of the population, and anyone with Sberbank Online can easily purchase shares of, say, Tesla.
What in the reaction to your report so far have you found unexpected, important or unpleasant?
So far, the response has come only from the Russian-speaking audience. Many people have thanked me for making them – and their problems – visible. This is a very important part of a sociologist’s work and, for me personally, the most important element of this entire story. In the process, I heard several new dramatic and painful accounts.
There has been some criticism, of course, but so far it has been emotional rather than substantive. Nothing unexpected has happened yet.
Can you share one of those dramatic stories? Without names or anything that could identify the people involved, of course.
Here’s a quote: “the issue of frozen assets is a very important one – my wife’s brother was left destitute, [caring for] three elderly relatives and a daughter with advanced cancer. I am helping as best I can, but I am not doing so well myself… [All the more so] considering that he was planning, let’s say, a backup country with that money…”
Do you not have the sense that those whom you are addressing with the report are simply incapable of hearing or understanding you? What stops you from saying “yes”? By the way, whom exactly are you addressing?
I have the impression that there was a confusion in terminology from the very beginning. Something similar happened when everyone who left Russia after February 2022 was called relokanty. But relokanty have an existing job abroad, whereas most emigrants in that wave had no such job, apart from IT specialists.
There was similar confusion with frozen private assets: everyone was speaking about corrupt money, about “Russian money,” while the frozen assets of ordinary individuals simply vanished from view. This happens often, and it is precisely the kind of situation where public sociology is necessary and important, in my view.
If, because of the freeze, a negative attitude toward the West is growing among those who were previously loyal or positive toward it, how can this be imagined or measured?
Surveys among holders of foreign accounts or assets should be an effective tool. Data from international research centers (Gallup, Pew Research Center, etc.) on trust in Western institutions can also help assess the situation. There are also indirect indicators. Behavioral changes are well documented: for example, cases of companies transferring assets from Western jurisdictions to “neutral” ones (e.g., the UAE, Kazakhstan, Turkey, Armenia); declining investment flows, account openings, startups and relocations to Western countries; and an increase in requests for legal asset relocation.
The evolution of attitudes can also be traced in the media and is quite perceptible for content analysis. Take the emergence of the narrative “the West is unpredictable, property rights there are not protected”; the shift of groups that were previously supporters of the West to a position of “cautious distance” or open criticism; and higher receptivity to anti-Western rhetoric.
What conclusions have you drawn about the impact of this freeze on the growth of anti-Western sentiment among young, educated and active people? Is there any clear example of disillusionment with Western values?
To provide such an assessment, a separate study would be necessary, with in-depth interviews, social media analysis and a quantitative survey. But if we take a simpler approach and use social imagination, it is not hard to picture the following: for many in this group, the West was not merely a place with wealth, but also one where rules worked. They disliked the Russian government precisely for its “legal nihilism,” corruption and disregard for the law. The freeze could be one of the factors contributing to their disillusionment with Western institutions.
According to brokers, those over 60 make up 6.4% of all affected clients; in our survey, those over 60 constitute 5.2%. Brokers’ data does not allow us to determine where these individuals live. Our data includes a distribution by type of settlement (municipality), but this group is still relatively small within the survey. In the report, we noted that the survey reflects the most active and affluent segment of the affected population.
It is important to emphasize that, statistically, there could certainly be pensioners among the investors. Investing is accessible to a broad segment of the population, and anyone with Sberbank Online can easily purchase shares of, say, Tesla.
What in the reaction to your report so far have you found unexpected, important or unpleasant?
So far, the response has come only from the Russian-speaking audience. Many people have thanked me for making them – and their problems – visible. This is a very important part of a sociologist’s work and, for me personally, the most important element of this entire story. In the process, I heard several new dramatic and painful accounts.
There has been some criticism, of course, but so far it has been emotional rather than substantive. Nothing unexpected has happened yet.
Can you share one of those dramatic stories? Without names or anything that could identify the people involved, of course.
Here’s a quote: “the issue of frozen assets is a very important one – my wife’s brother was left destitute, [caring for] three elderly relatives and a daughter with advanced cancer. I am helping as best I can, but I am not doing so well myself… [All the more so] considering that he was planning, let’s say, a backup country with that money…”
Do you not have the sense that those whom you are addressing with the report are simply incapable of hearing or understanding you? What stops you from saying “yes”? By the way, whom exactly are you addressing?
I have the impression that there was a confusion in terminology from the very beginning. Something similar happened when everyone who left Russia after February 2022 was called relokanty. But relokanty have an existing job abroad, whereas most emigrants in that wave had no such job, apart from IT specialists.
There was similar confusion with frozen private assets: everyone was speaking about corrupt money, about “Russian money,” while the frozen assets of ordinary individuals simply vanished from view. This happens often, and it is precisely the kind of situation where public sociology is necessary and important, in my view.
If, because of the freeze, a negative attitude toward the West is growing among those who were previously loyal or positive toward it, how can this be imagined or measured?
Surveys among holders of foreign accounts or assets should be an effective tool. Data from international research centers (Gallup, Pew Research Center, etc.) on trust in Western institutions can also help assess the situation. There are also indirect indicators. Behavioral changes are well documented: for example, cases of companies transferring assets from Western jurisdictions to “neutral” ones (e.g., the UAE, Kazakhstan, Turkey, Armenia); declining investment flows, account openings, startups and relocations to Western countries; and an increase in requests for legal asset relocation.
The evolution of attitudes can also be traced in the media and is quite perceptible for content analysis. Take the emergence of the narrative “the West is unpredictable, property rights there are not protected”; the shift of groups that were previously supporters of the West to a position of “cautious distance” or open criticism; and higher receptivity to anti-Western rhetoric.
What conclusions have you drawn about the impact of this freeze on the growth of anti-Western sentiment among young, educated and active people? Is there any clear example of disillusionment with Western values?
To provide such an assessment, a separate study would be necessary, with in-depth interviews, social media analysis and a quantitative survey. But if we take a simpler approach and use social imagination, it is not hard to picture the following: for many in this group, the West was not merely a place with wealth, but also one where rules worked. They disliked the Russian government precisely for its “legal nihilism,” corruption and disregard for the law. The freeze could be one of the factors contributing to their disillusionment with Western institutions.
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