According to information from the Treasury, in coordination with the European Commission, it was decided that investors had sufficient time to submit applications, and if they have not done so by now, such behaviour is regarded as tacit consent to the blocking of assets.

Lawyers are challenging this decision, pointing to the absence of a legal basis for stopping the acceptance of applications, as well as to a violation of property rights, which may effectively amount to confiscation. Nevertheless, Treasury representatives believe they have sufficient discretionary powers as a regulator to implement this decision.

What does this mean in practice?

Investors who still have doubts should urgently submit an application for a licence. It is advisable to prepare the most complete set of documents possible now (it can be supplemented later) and submit the application no later than September 2025, and preferably during the summer period.

It is important to understand that the Belgian licence is the “master” licence, without which any other licences (for example, at EU level or at the level of individual countries) lose their meaning.

Additional information

Treasury representatives also emphasised that they will not issue licences for assets sold within Russia if the new owner applies for a licence. However, this restriction does not apply to donation agreements, as in such cases there is no financial or economic consideration.

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