Have you ever watched a heist movie where the robbers find a clever legal loophole right at the last second to pull off the impossible score? That’s exactly what the European Union is attempting right now – except the vault belongs to Russia, the loot is roughly a quarter-trillion dollars, and the getaway driver is getting cold feet.
Deep inside Brussels, something extraordinary is happening. EU leaders are rushing to permanently freeze – and ultimately spend – more than €210 billion of Russian central bank assets before anyone can slam on the brakes. And the biggest brake pedal in the room belongs to one man: Viktor Orbán.
The Great Brussels Bypass
For years, sanctions against Russia have required unanimous agreement among the 27 member states. Every six months the package comes up for renewal, and every six months Hungary threatens to veto unless it gets concessions. It’s become a predictable dance.
But this time feels different. The patience has run out. With Ukraine burning through money faster than ever and war fatigue spreading across the West, the European Commission has decided to change the rules of the game entirely.
Enter the nuclear option: emergency powers and qualified majority voting. Instead of asking nicely for unanimous consent, the plan is to push through a permanent freezing mechanism that only needs 55% of member states representing 65% of the population. Suddenly one country – even a stubborn one – can’t hold everyone else hostage.
How Much Money Are We Talking About?
The numbers are eye-watering. Of the roughly €300 billion in Russian central bank assets frozen worldwide after the 2022 invasion, about 70% sits inside the European Union. The vast majority of that – around €190 billion – is held by a single Belgian clearing house called Euroclear.
The new plan would transform these temporarily frozen reserves into a permanent funding stream for Ukraine. Officials are discussing releasing roughly €90 billion over the next two years alone, with the rest potentially following later. In plain language: Brussels wants to turn seized Russian money into what some are already calling a “reparations loan.”
We have to use every tool at our disposal to support Ukraine for as long as it takes.
– Senior EU official, speaking anonymously to reporters
Why Now? The Clock Is Ticking
Several deadlines are converging at once. The current sanctions package needs renewal again in January. Nobody wants another public fight with Budapest right before Christmas. More importantly, there’s growing fear that the incoming U.S. administration might push for a quick peace deal that would force Europe to return the assets.
By moving fast and making the freeze permanent, Brussels hopes to remove those assets from the negotiating table entirely. It’s a classic case of “what’s done is done.” Once the money is gone, it’s a lot harder to give it back.
In my view, this is less about creative financing and more about political survival. European leaders promised Ukraine the moon, but public support is crumbling. Seizing Russian assets looks like a magic solution – free money that doesn’t come from European taxpayers. The temptation is enormous.
Belgium’s €190 Billion Nightmare
Here’s where things get really interesting. The country holding most of the Russian money isn’t Germany or France – it’s little Belgium. And Belgium is not happy.
Belgian Prime Minister Bart De Wever has been unusually blunt, reportedly calling the idea “complete madness” in private meetings. His fear is simple: if Russia ever wins a legal case or negotiates a peace deal that requires returning the assets, someone will have to write a €190 billion check. And that someone will almost certainly be Belgium.
- Euroclear is headquartered in Brussels
- Belgian courts would likely handle any Russian lawsuits
- The Belgian state could be held ultimately responsible
- No other EU country faces the same direct exposure
Think about that for a second. One mid-sized European country could theoretically go bankrupt because of a decision made by 27 nations. No wonder Belgian officials are demanding iron-clad guarantees that everyone else will share the pain if things go south.
What Could Russia Actually Do?
Moscow hasn’t been quiet. Russian officials have swung between icy legal warnings and outright threats. Former president Dmitry Medvedev went as far as calling the seizure a casus belli – diplomatic Latin for “reason for war.”
But war isn’t the most likely response. Russia has plenty of asymmetric weapons in its arsenal:
- Seizing Western assets inside Russia (estimated at $288 billion)
- Nationalizing European companies still operating on Russian soil
- Freezing or confiscating European-owned securities held in Russian depositories
- Targeted legal action against Euroclear specifically
- Cutting remaining energy ties or sabotaging undersea infrastructure
The scariest part? Russia has already started preparing. Officials have openly discussed creating a mirror list of Western assets to seize in retaliation. Some European companies with factories in Russia are reportedly moving assets offshore as fast as they can.
The Hungarian Stand – And Why It Matters
Viktor Orbán has built his entire European strategy around the veto. It’s his leverage, his bargaining chip, his way of reminding everyone that Hungary still matters. Losing that power on something this big would be devastating for his domestic image.
His argument is brutally pragmatic: if Brussels takes Russian assets, Moscow will take European assets in return. Hungarian companies – particularly in energy and banking – have significant investments inside Russia. Why should Budapest vote to put its own businesses at risk?
If Hungarian companies lose their assets in Russia, why should Hungary support such a move?
– Statement from the Hungarian government, October 2025
It’s a fair question, even if most European leaders don’t want to hear it.
The Legal Minefield
International law wasn’t exactly written with this scenario in mind. Freezing assets after an invasion? Perfectly legal. Confiscating them permanently to fund the victim country? That’s never been tested at this scale.
Russia will undoubtedly challenge any permanent seizure in every court that will hear the case – from Brussels to New York to Singapore. Legal experts are divided. Some say the EU has a strong case under countermeasure doctrines. Others warn this could destroy the entire principle of sovereign immunity for central bank assets.
If courts eventually rule against the EU, the financial fallout could be catastrophic. Imagine having to return €210 billion plus decades of interest and legal penalties. It would make the Greek debt crisis look like pocket change.
What Happens on December 18?
That’s the date everyone is circling. EU leaders will gather in Brussels for what promises to be one of the most tense summits in years. The new council president, António Costa, has already warned he’ll keep them talking “for days if necessary” until they reach a deal.
Behind the scenes, frantic negotiations continue. Germany and Spain are pushing hard for the seizure. France appears supportive but quiet. Smaller countries worry about retaliation. Belgium wants written guarantees in blood.
And Hungary? Hungary is preparing to fight until the very last vote.
In many ways, this is the moment Europe’s unity gets truly tested. For three years the EU has presented a remarkably united front against Russia. Now, for the first time, that unity is cracking over money – specifically, whose money gets taken and who bears the risk.
The decision made in Brussels this month won’t just affect Ukraine’s ability to keep fighting. It will shape Europe’s relationship with Russia for decades. It might determine whether central bank assets remain untouchable in future conflicts. And it could very well decide whether the European project itself survives intact.
Sometimes the biggest risks don’t come from battlefield defeats. They come from reaching too far for what looks like easy money.
As one seasoned diplomat told me recently: “We wanted to punish Russia. Instead we might end up punishing ourselves.”
