Being on the EU sanctions list against Russia does not make the bills disappear. Rent, taxes and lawyers still have to be paid. A freeze is not a confiscation: the Regulation provides for derogations, which the national authority may grant case by case. In Belgium, the Treasury decides.<\/p>\n
Regulation (EU) No 269\/2014, which governs the asset freeze linked to the war in Ukraine, entrusts derogations to the competent authorities of the Member States. In Belgium, this is the General Administration of the Treasury of the FPS Finance, Avenue des Arts 30, 1040 Brussels, reachable at quesfinvragen.tf@minfin.fed.be.<\/p>\n
In practice, the request goes to the authority of the Member State where the funds are frozen. Assets frozen at a Belgian bank therefore fall under the Belgian Treasury, even if their owner lives elsewhere.<\/p>\n
Article 4 of the Regulation allows funds to be released for:<\/p>\n
The word “reasonable” matters. A precise engagement letter, with a rate and a budget, is more easily accepted than a global retainer.<\/p>\n
Two further derogations concern the past.<\/p>\n
Article 5<\/strong> allows certain arbitral, judicial or administrative decisions to be enforced, for example to pay a creditor. The conditions are strict: the funds are used exclusively to satisfy the claim, the decision does not benefit a listed person, and its recognition is not contrary to public policy. An arbitral award must have been rendered before the listing.<\/p>\n Article 6<\/strong> allows the listed person to pay what is due under a contract concluded, or an obligation that arose, before the listing. The payment may not be made available, directly or indirectly, to a listed person.<\/p>\n The Regulation contains further, more targeted derogations: divestment from a listed entity, humanitarian operations, safety, agricultural and food products. Several came with deadlines that have now passed. Always check the consolidated version in force.<\/p>\n An authorisation does not release the account. It allows a specific payment, on the conditions set by the Treasury. Everything else remains frozen.<\/p>\n Amounts arriving on a frozen account, such as interest or a payment due under an earlier contract, may be credited to it. They are frozen in turn, and the bank informs the Treasury without delay (Article 7).<\/p>\n Finally, the authorisation must precede the payment. The Council’s best practices state that it is given in writing, before the funds are used or made available. They add that a listed person cannot rely on the freeze to justify a payment default if no authorisation was requested.<\/p>\n When an account is held by a listed person and a person who is not listed, the whole account is in principle frozen. The non-listed co-holder is not without remedy: under the Council’s best practices, they may request an authorisation, where appropriate by ending the joint ownership so that their share can be released. They will have to prove, with documents, what belongs to them.<\/p>\n A few common-sense rules increase the chance of a prompt answer:<\/p>\n In practice, processing times remain long and applicants need patience.<\/p>\n A refusal by the Treasury is an administrative decision. It can be challenged before the Council of State, which has already annulled a refusal to release assets<\/a>.<\/p>\n A well-documented request also protects the bank. It executes the payment on the basis of a written authorisation, within clear limits.<\/p>\n Situation at 27 May 2026. This article is for general information only and does not constitute legal advice.<\/em><\/p>\n <\/p>\n <\/p>\n","protected":false},"excerpt":{"rendered":" Being on the EU sanctions list against Russia does not make the bills disappear. Rent, taxes and lawyers still have to be paid. A freeze is not a confiscation: the Regulation provides for derogations, which the national authority may grant case by case. In Belgium, the Treasury decides. Key points Frozen funds stay frozen. A… Continue Reading →<\/a><\/p>\n","protected":false},"author":185562167,"featured_media":11194,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_coblocks_attr":"","_coblocks_dimensions":"","_coblocks_responsive_height":"","_coblocks_accordion_ie_support":"","advanced_seo_description":"Sanctioned person or frozen assets in Belgium? Basic needs, legal fees, earlier contracts: the derogations available and how to request them from the Treasury.","jetpack_seo_html_title":"Frozen assets in Belgium: Treasury derogations","jetpack_seo_noindex":false,"jetpack_seo_schema_type":"","_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":true,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_wpcom_ai_launchpad_first_post":false,"_jetpack_hide_featured_image":false,"_jetpack_featured_image_duplicate_dismissed":0,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_post_was_ever_published":false},"categories":[11430987],"tags":[],"class_list":["post-11233","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-international-sanctions","clear","fallback-thumbnail"],"jetpack_likes_enabled":true,"jetpack_sharing_enabled":true,"jetpack_shortlink":"https:\/\/wp.me\/pbYDZD-2Vb","jetpack-related-posts":[],"jetpack_featured_media_url":"https:\/\/i0.wp.com\/bankinglaw.be\/wp-content\/uploads\/2026\/10\/avoirs-geles-derogations-tresorerie.jpg?fit=1200%2C630&ssl=1","_links":{"self":[{"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/posts\/11233","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/users\/185562167"}],"replies":[{"embeddable":true,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/comments?post=11233"}],"version-history":[{"count":3,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/posts\/11233\/revisions"}],"predecessor-version":[{"id":11274,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/posts\/11233\/revisions\/11274"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/media\/11194"}],"wp:attachment":[{"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/media?parent=11233"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/categories?post=11233"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/bankinglaw.be\/en\/wp-json\/wp\/v2\/tags?post=11233"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}An authorisation is not an unfreezing<\/h2>\n
Joint accounts<\/h2>\n
How to file the request<\/h2>\n
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On the same topic<\/h3>\n
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