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13 / 03 / 2025
The window is narrowing: missing the filing deadline will complicate or make impossible the unblocking of assets through the NSD—Euroclear chain
Soon it will be three years since NSD was added to the EU sanctions list. In this regard, investors whose assets are blocked in Euroclear should understand the risks associated with missing the deadline for obtaining a license from the Belgian Treasury.


  • If an application is submitted to the Belgian Treasury after four years, there is a risk of refusal based on the principle of a reasonable period for expecting a license request.

  • The refusal may be challenged in court within 60 days. At the same time, the case consideration period is from one year or more.

  • In addition, Belgium provides a statute of limitations for private investors, which is five years. After this period expires, and if the Belgian Treasury refuses to accept the application, the investor will have no opportunity left to protect their legitimate interests in relation to the blocking of assets.

 

Thus, delaying the filing of the application may significantly complicate the process, resulting in additional expenses and increasing the time needed to gain control over the assets.

This issue really requires prompt resolution, especially given the approaching deadlines. The sooner investors submit an application to the Belgian Treasury, the higher the chances of a successful resolution.

Key points:

  1. If an application is filed after 4 years, there is a risk of refusal based on the principle of a reasonable period for expecting a license request.

  2. Statute of limitations – 5 years: if it is missed, the legal avenues for protection will be exhausted.

  3. Judicial challenge to a refusal will take one year or more, which will increase costs and waiting time.


⚠ What should be done now?

  • Assess the situation: if the necessary conditions are met (see more https://разблокировка.com/group, it is advisable to start the application process without delay.

  • Consult with lawyers: preferably those who already have experience submitting applications to the Belgian Treasury. Alpine Tax has positive experience in obtaining licenses (to date, 5 licenses have been obtained from the Belgian Treasury) and OFAC - USA (Case IDs have been received for 7 applications).



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