As prospects for a peace settlement in Ukraine remain stalled, a growing number of foreign companies still operating in Russia are seeking ways to withdraw their stranded assets from the country. Russian investors, meanwhile, have a reciprocal interest: securities and cash worth hundreds of billions of roubles remain blocked in Western jurisdictions. Against this backdrop, lawyers, consultants and brokerages have increasingly begun promoting private mechanisms for exchanging such assets. How viable are these arrangements?
Foreign interest
Since early 2026, companies from so-called “unfriendly” countries have stepped up efforts to monetize their Russian assets, many of which have effectively been left stranded, RBC reported in April. These assets include not only funds held in special Type-C accounts, but also balances on ordinary accounts and undistributed dividends. Some subsidiaries of Western corporations have refrained from distributing accumulated profits altogether, given the limited prospects of moving such payments to their home countries. Foreign businesses face an increasingly difficult environment as Russian authorities now rarely grant permission for dividend transfers or the repatriation of proceeds from certain transactions to “unfriendly” jurisdictions.
Experts surveyed by RBC say this reflects a broader shift in sentiment among Western companies that have remained in Russia so far. With odds for geopolitical normalization appearing increasingly uncertain, some businesses have concluded that a full exit is the only realistic option. For many, one of the few viable pathways involves asset swap arrangements with non-sanctioned Russian investors whose foreign securities remain frozen in institutions such as Euroclear and Clearstream. In 2024, Russian brokerage Investitsionnaya Palata completed two rounds of centralized asset exchanges under Presidential Decree No. 844, though the results were limited, with total transaction volumes amounting to just 10.6 billion rubles ($141.5 million).
Transaction nuances
A number of Russian financial market participants and advisory firms, including Alphabet, are now putting forward models designed to unlock such assets through swap transactions. Under such model, no cross-border transfer formally takes place: funds originally owned by foreign companies remain within Russia.
In practice, the arrangement could work as follows: a Russian investor cedes rights to securities or other assets blocked in Europe — or in some cases the US — such as shares in European or American firms, to a foreign parent company or one of its affiliates. In exchange, the Russian party would receive frozen funds held by a Russian subsidiary of the Western company, effectively as payment for the overseas assets.
For such a transaction to proceed, approval is required from multiple regulators. On the Russian side, the deal must be authorized by the special subcommittee of the government commission overseeing foreign investment. It must also secure clearance from the relevant regulator in an EU jurisdiction and, in some cases — particularly where US securities are involved — from the US Office of Foreign Assets Control (OFAC).
Because European regulatory approval is granted independently of Russia’s reciprocal measures, a Russian escrow agent is also needed, Dmitry Sherstobitov, managing partner at Alphabet, told RBC. Under this structure, funds belonging to the Russian subsidiary of a Western holding company are placed in escrow at the outset of the process. This serves as an additional safeguard, ensuring that the Russian party ultimately receives payment for transferred assets abroad.
A successful swap example (theoretically): a Russian subsidiary of a Western group seeks to pay dividends to its EU-based shareholder. Approval from Russia’s subcommittee would be more likely if the full dividend amount remains within Russia rather than being transferred abroad. Applicable taxes could also be paid into the Russian budget as part of the arrangement. In return, the Western parent company would receive assets owned by a designated Russian investor that remain blocked in Europe.
Prospects for success
Although several similar transactions are currently being pursued, there have been just a few successfully completed cases, according to experts interviewed by RBC. As a result, the most commercially rational model is a success-fee arrangement, under which intermediaries are compensated only if the transaction is ultimately completed.
Lawyers believe regulators on both sides may prove more receptive to such transactions. In 2025, the Belgium’s Treasury (Belgium is the home country to Euroclear, Europe’s largest securities depository) reportedly stopped approving applications to unfreeze Russian investors’ assets. However, Russian media reported in April 2026 that the Belgian authorities had resumed reviewing such applications after resolving a certain bureaucratic issue.
According to Alphabet, the most favourable scenario for a successful asset swap is one in which a Russian party had already applied, before January 7, 2023, to unblock its assets through a collective application, and that request was either not rejected or, if initially denied, was successfully appealed. January 7, 2023, marked the formal deadline under EU sanctions regulations for submitting applications through the general licenses issued by Belgium and Luxembourg for the release of assets held in Euroclear or Clearstream via Russia’s sanctioned National Settlement Depository (NSD).
The likelihood of success increases significantly when a large foreign company can be matched with a sufficiently substantial Russian investor, Sherstobitov says. Since late 2025 a number of Russian brokerages have been devising schemes that pool blocked foreign securities held by Russian clients for potential exchange. However, aggregating such assets materially complicates execution. To match sizeable frozen funds held by foreign companies in Russia, brokers would need to assemble numerous smaller Russian holdings — each of which would typically require separate regulatory approval in Europe.