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Luxembourg enables Russian investors to unblock assets held in NSD accounts with Clearstrea

DATE: December 28, 2022 | AUTHOR: AT

On December 20, 2022, the Luxembourg Ministry of Finance issued a general license that permits to unblock assets of Russian investors held in the accounts of the Russian National Settlement Depository (NSD) with the international depository Clearstream, registered in Luxembourg.

The permit is valid until January 7, 2023. This time is given to Russian investors not subject to private sanctions in order to transfer their assets from NSD account to accounts of other depositories or sell securities.

According to the general license, after brokers and depositories of the investors withdraw their accounts from the NSD, they have to submit to the Luxembourg Ministry of Finance:

  • written evidence of the termination of any agreements concluded with NSD within 10 days from its termination and no later than 5 business days beginning January 7, 2023;
  • written evidence that the agreements concluded with NSD were concluded prior to June 3, 2022.

In case of non-compliance with this procedure, brokers and depositories of the investors will be subject to administrative or criminal liability.


Whether any action is required from the investors themselves, will depend on the particular broker. If you have securities that are held in a brokerage account with Clearstream, we advise you to check with your broker whether he or she is taking any action to unfreeze the accounts. At the time of preparing of this information letter, there is no information as to whether a similar decision will be taken by the Belgian Treasury with respect to Euroclear.

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