The Bank of Russia sued Euroclear in the Moscow Arbitrazh Court for 18.2 trillion rubles (about $250B) over losses it attributes to the EU freeze of Russian assets. The court granted the claim in full in May 2026, and a Russian cassation court rejected Euroclear’s appeals on October 22, 2026. Euroclear is seeking to block recognition in Brussels, while the Bank of Russia challenges an EU regulation at the General Court.
Latest development Oct 22, 2026
On October 22, 2026, the Moscow District Arbitrazh Court, sitting in cassation, rejected Euroclear’s two cassation appeals against the Bank of Russia’s damages judgment. The court left the rulings of the first-instance court and the Ninth Arbitrazh Court of Appeal unchanged.
Why it matters
The dispute tests whether Western custodians can be made to answer in Russian courts for Russian assets frozen under EU sanctions. It also tests whether EU law can block recognition of the resulting judgments, and it bears on the EU’s debate over using those assets to fund Ukraine.
Background
The dispute grows out of the West’s freeze of roughly €300B in Russian central bank assets after Russia’s 2022 invasion of Ukraine. Euroclear Bank SA/NV, the Brussels-based securities depository, holds about €190B to €200B of those immobilized funds. In late 2025, the European Union debated turning the frozen assets, or the profits they generate, into a reparations loan for Ukraine. The Central Bank of the Russian Federation (Bank of Russia) responded in its own courts.
On December 12, 2025, the Bank of Russia sued Euroclear in the Moscow Arbitrazh Court. It sought 18.2 trillion rubles, then worth about $250B, for the frozen principal and for lost profits it says it was denied. The case is one of several parallel Russian lawsuits against Euroclear brought under Russia’s counter-sanctions procedural rules, alongside smaller claims from Russian companies and banks such as Bank Saint-Petersburg and Silicium-2. At the Bank of Russia’s request, the court held a closed-door preliminary hearing on January 16, 2026. It rejected Euroclear’s motion to dismiss the claim on January 19 and granted the claim in full on May 15, 2026.
Euroclear has refused to recognize the Russian proceedings from the start, arguing they violate its right to a fair trial and conflict with EU sanctions law. The Moscow court granted immediate enforcement over Euroclear’s objections on May 26, 2026, and the Ninth Arbitrazh Court of Appeal upheld that order on June 8. On June 30, 2026, Euroclear sued the Bank of Russia in the Brussels Enterprise Court. It seeks a declaration that the Moscow judgment cannot be recognized or enforced in Belgium because it conflicts with EU Regulations 269/2014 and 833/2014 and with Belgian public policy. On July 16, 2026, the Ninth Arbitrazh Court of Appeal rejected Euroclear’s appeal, making the judgment final and enforceable inside Russia.
On July 23, 2026, the EU adopted Council Regulation 2026/1848, whose Article 1(28) restricts recognition of Russian court decisions in EU member states. On September 15, 2026, the Bank of Russia challenged that provision at the General Court of the European Union in Luxembourg. It argues the measure unlawfully blocks recognition and enforcement of the Moscow judgment outside Russia and infringes principles of access to justice and sovereign immunity. Euroclear filed two cassation appeals on September 24, 2026, but the Moscow District Arbitrazh Court, sitting in cassation, rejected them on October 22, 2026. The Bank of Russia now holds a judgment enforceable inside Russia for a sum that exceeds Euroclear’s own balance sheet.
Timeline 14 events
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AppealMoscow cassation court rejects Euroclear’s appeals
Acting as the cassation instance, the Moscow District Arbitrazh Court dismissed both appeals. It upheld the first-instance and appellate rulings ordering Euroclear to pay roughly €200B to the Bank of Russia.
Суд в Москве отклонил жалобу Euroclear на взыскание €200 млрд по иску ЦБThe court rejected Euroclear's cassation appeal for the recovery of 18.2 trillion rubles at the request of the Bank of RussiaThe court will consider Euroclear's complaint for the recovery of 200 billion euros on the claim of the Central Bank
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AppealEuroclear files two cassation appeals in Moscow
Euroclear lodged two cassation appeals with the Russian court system challenging the Bank of Russia’s damages claim. The appeals followed the Ninth Arbitrazh Court of Appeal’s rejection of its earlier appeal in July.
Euroclear files two cassation appeals against Russian Central Bank's claim
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FilingBank of Russia challenges EU regulation shielding Euroclear at General Court
The application targeted Article 1(28) of Council Regulation 2026/1848, adopted July 23, 2026. The Bank of Russia argued that the measure unlawfully blocks recognition and enforcement of the Moscow judgment outside Russia and infringes access to justice and sovereign immunity.
Russian Central Bank Challenges EU Regulation Blocking $230Bln Claim Against EuroclearBank of Russia files claim with EU General Court to challenge restrictions on recognition and enforcement of Russian court orders in other jurisdictionsRussia takes EU to court over sanctions rule shielding Euroclear from Russian judgments
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AppealNinth Arbitrazh Court of Appeal rejects Euroclear’s appeal, judgment enters into force
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FilingEuroclear sues Bank of Russia in Brussels to block Moscow judgment
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Appeal
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AppealEuroclear challenges immediate enforcement order
Euroclear filed a complaint with the Moscow Arbitrazh Court against the order for immediate enforcement of the judgment.
Euroclear appeals immediate enforcement of $256 bln Central Bank ruling
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EnforcementMoscow court grants immediate enforcement
The Moscow Arbitrazh Court granted the Bank of Russia’s motion to enforce the judgment immediately, ahead of any appellate ruling.
Court grants Bank of Russia's motion to enforce court decision in lawsuit vs Euroclear
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OrderBank of Russia moves for immediate enforcement
The Bank of Russia filed a motion with the Moscow Arbitrazh Court to immediately enforce the judgment before any appeal was resolved.
Euroclear appeals immediate enforcement of $256 bln Central Bank ruling
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OtherEuroclear says it will appeal the ruling
Euroclear publicly rejected the Moscow court’s payment order and said it would appeal, calling the process a violation of its fair trial rights.
Euroclear rejects $254bn payment order in Bank of Russia case
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JudgmentMoscow Arbitrazh Court grants the claim in full after a closed-door trial
The court ordered Euroclear to pay losses in seven currencies totaling about 18.17 trillion rubles, and later granted the Bank of Russia’s motion for immediate enforcement.
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OrderCourt rejects Euroclear motion to dismiss
In a closed session, the Moscow Arbitrazh Court rejected Euroclear’s motion to dismiss the Bank of Russia’s claim without consideration.
Court rejects Euroclear's motion to dismiss Russian Central Bank's claim without consideration
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HearingMoscow court holds preliminary hearing
Judge Anna Petrukhina ruled the case would proceed behind closed doors at the Bank of Russia’s request to protect banking secrecy.
Moscow Court Holds Preliminary Hearing in Central Bank Lawsuit Against Euroclear
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FilingBank of Russia sues Euroclear in Moscow for 18.2 trillion rubles
Experimental AI forecast
How it is madeHow will the Brussels Enterprise Court rule at first instance on Euroclear’s action to block recognition of the Bank of Russia’s Moscow judgment in Belgium by April 30, 2028?
- Brussels court blocks Moscow judgment53%
- Still pending on April 30, 202837%
- Brussels court dismisses Euroclear’s case8%
- Brussels court rejects Euroclear’s claim2%
- Resolves by
- Apr 30, 2028in 18 months
- Record confidence
- Low
The most likely outcome, at 53%, is that the Brussels Enterprise Court declares the Moscow judgment unrecognizable in Belgium by April 30, 2028. EU Regulation 2026/1848 now expressly restricts recognition of Russian court decisions, which gives Euroclear a strong statutory basis. The main uncertainty is timing, since the record shows no Brussels hearing schedule.
How it resolves. Resolves on the first-instance judgment of the Brussels Enterprise Court in Euroclear’s June 30, 2026, action, as shown by court records, party statements, or reliable press reports. “Blocks” means the court declares the Moscow judgment unrecognizable or unenforceable in Belgium, in whole or in substantial part. “Rejects on the merits” means the court refuses that declaration after reaching the merits. “Dismisses” means the court declines jurisdiction or finds the action inadmissible, including for lack of interest, or Euroclear withdraws. If no first-instance judgment issues by April 30, 2028, it resolves as still pending.
Reasoning
Starting point. First-instance rulings by EU member-state courts on recognition of Russian counter-sanctions judgments against Western financial firms, and Belgian commercial court case durations: EU courts rarely recognize judgments that conflict with sanctions law or public policy (likely over 90% refusal). Belgian commercial cases often take 12 to 24 months to reach first-instance judgment.
The previous question resolved when the cassation court upheld the judgment on October 22, 2026, so this forecast asks a new question and does not compare numbers. With Russian appeals exhausted, the next decisive step outside Russia is the Brussels ruling on Euroclear’s non-recognition action. EU courts rarely give effect to judgments that conflict with sanctions regulations or public policy, and Article 1(28) of Regulation 2026/1848 now directly restricts recognition. The Bank of Russia’s General Court challenge to that provision will likely take about two years, so the provision should remain in force while Brussels decides. The leading alternative is delay. Belgian first-instance cases often take 12 to 24 months, and the Bank of Russia may raise sovereign immunity or jurisdiction objections, or simply not appear, which could slow or speed the case. A smaller risk is that the court finds a preventive declaratory action inadmissible because no recognition request is pending in Belgium. A merits ruling favoring the Bank of Russia is a long shot given the regulation. The record lacks any procedural calendar, counsel, or hearing dates in Brussels, which limits confidence on timing.
Regulation 2026/1848 Article 1(28) restricts recognition of Russian judgments · No Brussels hearing schedule appears in the record · Possible sovereign immunity or admissibility objections by Bank of Russia · Pending General Court challenge unlikely to conclude first · Belgian public policy and EU sanctions no-claims principles
Previous forecast: correct “How will the Russian cassation court rule on Euroclear’s two cassation appeals against the Bank of Russia’s Moscow judgment by March 31, 2027?” (Sep 26, 2026). On October 22, 2026, the Moscow District Arbitrazh Court, acting as the cassation instance, rejected both of Euroclear’s cassation appeals. It upheld the lower rulings ordering Euroclear to pay roughly €200 billion to the Bank of Russia. It put “Cassation court upholds judgment” at 83%. Track record
Generated automatically by Claude Opus 5.5 on Oct 25, 2026 from this case’s record on this site, and published without editorial review. The probabilities are the model’s judgment, not measured frequencies, and they are scored publicly as cases resolve. Not legal or investment advice. How the forecasts are made
What it would mean
If the Brussels Enterprise Court blocks the Moscow judgment, the roughly $250B award would have no legal effect in Belgium. That is where Euroclear Bank holds about €200B of sanctioned Russian assets. No cash would move in Europe, and Euroclear’s core capital of about €9.2B would remain beyond the judgment’s reach there. Pressure would shift to Euroclear-linked assets inside Russia and in states such as China, the UAE, and Kazakhstan. A first-instance ruling could be appealed, and Fitch already rates the legal risk as remote over the next 12 to 18 months.
If the court instead rejects Euroclear’s claim, the Bank of Russia would gain an opening to seek recognition of a judgment many times larger than Euroclear’s capital. Enforcement would still run into the EU freeze and Article 1(28) of Regulation 2026/1848, so cash would not move quickly. The risk would shift toward Belgium and other member states. They would face pressure to back Euroclear before any EU structure takes over the assets. A procedural dismissal, at 8%, would leave Euroclear relying on the regulation alone, without a Belgian declaration to show courts elsewhere.
Money, who pays, markets and what to watch
Two steps ahead. The judgment roughly mirrors the frozen balance Euroclear owes the Bank of Russia. If the EU moves those assets into a separate structure, Euroclear could keep the Russian liability without the matching asset unless the claim moves with it. Euroclear can also recover losses from seizures in Russia out of frozen Russian balances under the 2024 derogation. If it does, Moscow’s enforcement would partly draw down its own frozen reserves.
The money
- Euroclear Bank: up to $250B. Face value of the Moscow judgment, about 18.17 trillion rubles in seven currencies, or about $250B per the record. TASS converted the same sum at $256B in May 2026 and $216B in September 2026. The low of zero reflects EU non-recognition and the continued freeze of the Russian-linked balances in Brussels. Collection would be limited to Euroclear-linked assets in Russia or in friendly states. Their value is not disclosed. Inside Russia, already enforceable through seizures since the May 26, 2026, immediate-enforcement order. In the EU, not while sanctions and Article 1(28) stand, and not before Belgian and EU court challenges end.[1][2] That is up to 24 times its equity or regulatory capital ($10.5B, Jun 2026), and up to 115 times its annual revenue ($2.2B, 2025).
- Figures used: Euroclear Bank, equity or regulatory capital $10.5B (Jun 2026)[3][4] · Euroclear Bank, annual revenue $2.2B (2025)[5][4] · Euroclear Bank, reserve for this litigation $390M (Dec 2025)[5][4]
Who pays
- Euroclear Bank is the named debtor. Its balance sheet stood at €241B at the end of June 2026, of which €202B related to sanctioned Russian assets.[6]
- Euroclear took a €342M provision in 2025 for material risks and uncertainties tied to Russian sanctions. It has disclosed no reserve for this judgment and calls the claim without merit.[5][3]
- Member states may share the risk. A Commission idea for an EU “bad bank” would spread residual Russian claims among them. A revived reparations loan would need guarantees Belgium accepts.[6][7]
- The frozen Russian pool itself is a payer of last resort. Under a December 2024 derogation, Euroclear released €3B of Russian assets to compensate clients whose holdings were expropriated in Russia.[8]
- Euroclear’s clients bear seizure risk inside Russia. The Financial Times reported that Russia had confiscated about €33B of Euroclear client assets.[8]
Markets
- Fitch confirmed Euroclear at AA with a stable outlook on July 7, 2026. It rated the liquidity and legal risks from the immobilized central bank assets as remote over 12 to 18 months.[3]
- Euroclear reported CET1 capital of about €9.2B and a CET1 ratio of about 55% at mid-2026. About €7.4B of its €16.7B in risk-weighted assets related to Russian assets.[3]
- Interest on Russian sanctioned assets was €5B in 2025, and Euroclear provisioned €3.3B as the EU windfall contribution. Underlying business income was nearly €1.9B.[5]
- Clearstream, owned by Deutsche Börse, falls under the same EU windfall rule but publishes no matching figure for Russian assets.[9]
- After the May 2026 judgment, Euroclear said its operations and financial position were unaffected by the court’s decision.[10][11]
Collecting
- Inside Russia, the judgment is final and immediately enforceable. The realistic targets are Euroclear’s remaining assets there, through seizures and court-ordered transfers.[4]
- China, the UAE, and Kazakhstan are possible venues for seizing Euroclear assets. No foreign court is known to have recognized the judgment, so these routes are a disruption risk rather than a collection path.[12]
- The Bank of Russia said, according to TASS, that it would choose enforcement routes in friendly and unfriendly jurisdictions once the judgment took effect. It also said it was considering international courts and arbitration.[1][2]
- Article 1(28) lets courts in EU member states forbid Russian parties from seeking recognition of such judgments in any jurisdiction, on pain of financial penalties.[13]
- Russian creditors compete for the same assets. More than 100 suits seek about $2.5B, Silicium-2 won $194.2M, and private investors want a share of any seized Euroclear assets.[4][14]
Beyond the parties
- A Belgian ruling would show whether custodians that obey EU sanctions can be held liable at home. 103 central banks rely on Euroclear to hold their reserves, and 70 rely on Clearstream.[8]
- The EU chose to borrow for a €90B loan to Ukraine and keep the Russian assets frozen until Moscow pays reparations. A Brussels block would protect the windfall income that still flows to Ukraine.[12][7]
- Euroclear had paid about €6.6B in windfall contributions by July 2026. These come from reinvesting the Bank of Russia’s cash balances.[15][7]
- EU courts have so far turned away Russian challengers. On October 2, 2026, the General Court dismissed as inadmissible actions by three Russian investors whose securities are held through the National Settlement Depository at Euroclear.[6]
- Belgian courts still police procedure. On September 11, 2026, the Council of State annulled a Treasury refusal to release BCS Bank assets because of a delegation defect, without ordering their release.[7]
What to watch
- Late 2026Bank of Russia announces enforcement steps against Euroclear-linked assets now that the judgment is final[1][2]
- Late 2026European Commission sets out an EU structure to take over the frozen assets from Euroclear[6]
- Early 2027Euroclear publishes full-year 2026 results with updated Russia provisions and litigation disclosures[5]
- 2027General Court proceeds on Bank of Russia challenges to Article 1(28) and to the indefinite freeze under Regulation 2025/2600[13]
Sources
- Euroclear files two cassation appeals against Russian Central Bank’s claim tass.com · 2026-09
- Euroclear appeals immediate enforcement of $256 bln Central Bank ruling tass.com · 2026-05
- Euroclear delivers sustained growth across core activities in H1 2026 euroclear.com · 2026-07
- Russian Firm Wins $194M Lawsuit Against Euroclear in Moscow themoscowtimes.com · 2026-07-28
- Euroclear delivers strong 2025 results euroclear.com · 2026-02
- Can an EU “Bad Bank” Protect Euroclear From Frozen Russian Assets and Claims While Still Funding Ukraine? disruptionbanking.com · 2026-10-14
- Why Is Euroclear Still Holding Over €200 Billion of Russian Money? disruptionbanking.com · 2026-09-30
- Euroclear and the geopolitics of immobilized Russian assets cepr.org · 2025-12
- How Much Russian Money Does Clearstream Hold and Who Bears the Risk? disruptionbanking.com · 2026-10-02
- Update on Russian sanctioned assets – May 2026 euroclear.com · 2026-05
- Russian Court Orders Euroclear to Pay Around $250Bln Over Frozen Assets themoscowtimes.com · 2026-05-16
- Moscow court rejects Euroclear appeal in frozen assets case, state media reports uk.finance.yahoo.com · 2026-07-16
- Moscow Sues in Luxembourg to Save Its Euroclear Award: the EU Anti-Enforcement Shield and Paris Courts kohenavocats.com · 2026-09
- Russian central bank’s $235 bln case against Euroclear adjourned until spring marketscreener.com · 2026-01
- Euroclear reports strong growth in business income and profit in Q1 2026 euroclear.com · 2026-05
Experimental AI analysis by Claude Opus 5.5 on Oct 25, 2026, built on the forecast above from this case’s record and public sources found by the model’s own web search. Figures are estimates as of the dates shown, and shares of value are computed by the site from the figures cited. Published without editorial review. Nothing here predicts the price of any security or is investment advice. How it is made