In response to the Russian Federation’s unprovoked and unjustified full-scale military aggression against Ukraine in February 2022, the European Union (EU) adopted a series of restrictive measures (hereinafter, sanctions) aimed at undermining Russia’s ability to continue its violations of international law. Among these measures was the immobilization of assets belonging to the Central Bank of Russia (CBR), in an amount to nearly €200 billion, most of which are held by the Belgium-based Central Securities Depository Euroclear.

Specifically, on 28 February 2022, the European Council adopted Decision (CFSP) 2022/335, amending Council Decision 2014/512/CFSP, to prohibit any transactions related to the management of reserves and assets of the CBR. This prohibition was mirrored in Article 1a(4) of Decision 2014/512/CFSP, effectively leading to the immobilization of the relevant assets held by financial institutions within EU Member States. 

In its regulations implementing sanctions, the EU has established their expiration dates and mechanisms for their periodic review. Notably, the latest version of the Council CFSP Decision 2014/512/CFSP (Article 9), provides: “This Decision shall apply until 31 July 2025… This Decision shall be kept under constant review. It shall be renewed, or amended as appropriate, if the Council deems that its objectives have not been met…” However, such an approach allows the EU sanctions policy to become a hostage of political pressure and blackmail. As currently the vector of the U.S. policy regarding Russian Federation and war in Ukraine has significantly changed, the possibility of lifting or weakening the EU sanctions against Russian Federation is growing as well. Despite the firm statement of the EU state leaders and officials that EU will not lift sanctions until Russia ends its aggression and compensates for the damage, some decision-makers privately express concern, fearing that if the Trump administration decides to lift U.S. sanctions as part of negotiations with the Russian Federation, certain EU member states might veto the next EU sanctions extension, reviewed every six months. This could happen even though none of the reasons for the sanctions application have been resolved, and the intensity of Russian crimes continues to escalate with the targeted attacks on the Kryvyi Rih residential area and the playground, on April 4, that murdered 20 people, including nine children, and the Sumy downtown on April 13, the Palm Sunday, that killed 34, being among the latest deadliest strikes on civilians. 

Therefore, there is a real risk that on July 31, 2025, the fate of EU sanctions—including the immobilization of Russian Central Bank assets—will be challenged again if a member state refuses to support the extension. Then the sanctions could expire, potentially resulting in the return of the assets to the Russian Federation. Moreover, even if the issue is resolved in July, the problem will return over again in January 2026. The political consequences of lifting sanctions—and especially of de-immobilizing Russian assets—would be catastrophic for both the EU and Ukraine. First and foremost, it would mean rewarding Russian aggression, sending a message of encouragement to the aggressor state to pursue its imperialist conquests. The return of €200 billion to Russia’s military budget would significantly escalate its war machine and aggressive ambitions. At the same time, the EU would lose a vital source of funding to repay the ERA Loan, and Ukraine would lose its only viable option to finance security and rearmament—leaving it vulnerable to renewed Russian aggression and further threats to European territory.

This brief highlights the legal and strategic role of sanctions in maintaining peace and responding to violations of international law. It argues that sanctions should remain in place until their objectives are fully achieved and all damages are compensated, rather than being subject to political discretion, time-bound reviews, or the political blackmail of individual member states. It outlines two possible paths for fortifying EU sanctions against political interference and trade-offs: either the EU Council adopts a more protective and legally grounded approach—already outlined in EU guidelines—that places the burden of proof during the regular reviews on those advocating for the lifting of sanctions, or, at a minimum, extends duration of sanctions reviews significantly, from the current 6 months to 24–36 months at least. Given current geopolitical dynamics, maintaining the existing approach poses serious risks to the European Union’s own security. The EU remains a strong international actor, fully committed to uphold international law and safeguard global peace and security.

The full version of the brief is available via the link.

This publication was prepared during the project, «Stronger Europe, United Front – Advancing Ukraine’s EU Membership for Greater Resilience and Security», was funded by the European Union. The content of this publication/video/material is the sole responsibility of the “ANTS” NGO and does not necessarily reflect the views of the European Union.