Canada Must Lead to Find Billions in Frozen Russian Assets

The following is a memo – co-led by ERIC, the Global Magnitsky Justice Campaign, and Razom for Ukraine – sent to Canadian ministers in late June 2026, calling for Canada to use recently enacted powers that may reveal up to $22 billion in frozen Russian state assets previously undetected by existing legislative tools. Finding this money is the first step to repurposing it to support both Ukraine’s defence and reconstruction – a step ERIC has long advocated.

You can also read an op-ed championing the move – written by Sir Bill Browder, international lawyer Yuliya Ziskina, and ERIC Senior Security Policy Fellow Aaron Gasch Burnett – in the Toronto Star.

Memo

To: The Honourable Anita Anand, Minister of Foreign Affairs of Canada; The Honourable François-Philippe Champagne, Minister of Finance and National Revenue of Canada

Cc: The Honourable Mona Fortier, Parliamentary Secretary to the Minister of Foreign Affairs of Canada; The Honourable Robert Oliphant, Parliamentary Secretary to the Minister of Foreign Affairs of Canada; The Honourable Ryan Turnbull, Parliamentary Secretary to the Minister of Finance and National Revenue of Canada; 

Date: June 24^th, 2026

RE: Identifying and independently freezing Russian state assets held within Canadian jurisdiction under recently enacted legislative power.

We ask the Canadian government to demonstrate leadership on frozen Russian state assets by taking one concrete step: use recently enacted legislation to confirm the true amount of frozen Russian state assets within Canadian jurisdiction and apply Canadian sanctions law, as the law requires. We believe Canadian financial institutions hold approximately $22 billion (CAD) of Russian Central Bank (RCB) funds, currently unidentified and unfrozen under Canadian law.

Approximately $22 billion in Russian state assets remain unidentified and unfrozen in Canada, in violation of Canadian sanctions law

Euroclear’s publicly available reports show about 7 percent of the frozen assets that it manages, an estimated $22 billion, are in Canadian dollars.[1] Parliamentary order paper questions confirm that the Government recognizes this too,[2] but Euroclear has treated the exact location of these CAD holdings as a commercial confidence. As explained below, the structure of correspondent banking makes it near-certain that Canadian institutions hold these funds. Because the accounts appear under Euroclear’s name rather than the RCB’s, Canada may never have detected or frozen them under its own sanctions, even though the EU’s freeze on Russian state assets at Euroclear already applies. The new legislative powers allow the Government to compel Canadian financial institutions to identify these funds, as Canadian law requires, and to impose its own freeze on those assets.

How can this be?

The funds are hiding in plain sight. They are held in correspondent accounts in Euroclear’s name at Canadian financial institutions. On those institutions’ books, the accounts look like ordinary Euroclear deposits, with nothing to flag them as Russian state property, so the sanctioned funds mix in with Euroclear’s other, non-sanctioned money. Canadian institutions may therefore hold billions of dollars in sanctioned property without knowing it. Until recently, Canada had no legal tool to make them look behind Euroclear’s name to the true owner. That tool now exists.

Detailed explanation

When the RCB held Canadian government bonds, it managed them through Euroclear, a securities depository and clearinghouse based in Belgium. As the bonds matured, they converted into cash, specifically Canadian-dollar deposits. Euroclear is not a Canadian bank and has no legal entity in Canada, so it cannot hold Canadian dollars itself. Instead, the matured funds flow into Euroclear’s accounts at Canadian financial institutions, likely the Bank of Canada or Canadian correspondent banks. In other words, the roughly $22 billion in CAD-denominated frozen Russian state assets that Euroclear reports almost certainly sits in correspondent accounts at Canadian institutions.

Euroclear’s own books record the RCB as the ultimate owner of these deposits. On the Canadian institutions’ books, however, the correspondent account appears simply under Euroclear’s name, with no clear sign that Russian state entities ultimately own the funds: the RCB, the National Wealth Fund (NWF), or the Russian Ministry of Finance, all three sanctioned under Canada’s Special Economic Measures Act (SEMA).

This is where the recently enacted Bill C-15 (Budget 2025 Implementation Act, No. 1), Division 18,[3] comes in. Division 18 amends SEMA to allow the Governor in Council to enact regulations requiring Canadian financial institutions to disclose to the Minister of Finance any “foreign property” in their possession or control. Crucially, “foreign property” reaches beyond property held in a sanctioned entity’s own name and covers any property in Canada that a sanctioned person or foreign state owns, holds, or controls, directly or indirectly. That word, “indirectly,” legally enables Canada to look through Euroclear’s Canadian accounts to identify the beneficial owner. The Canadian correspondent account stands in Euroclear’s name, but Euroclear holds the specific deposits within it on the RCB’s behalf, and the RCB still owns them indirectly. Those deposits are therefore “foreign property” of a sanctioned entity, and Division 18 lets the Government compel the institution holding the account to ask Euroclear how much of the balance the RCB beneficially owns, and to report the answer.

Once the Government passes regulations under Division 18 requiring this disclosure, Canadian institutions must immediately question Euroclear about RCB assets and report the results to the Minister of Finance. For the first time, this will conclusively detail how much sanctioned Russian state money Canadian institutions hold.

If the assets are already frozen, why should Canada find them and freeze them again?

The EU has frozen these assets at the Euroclear level, but Canada has never identified or independently frozen them under its own law. Doing so matters for three reasons.

1. Canadian law requires it. 
   When a sanctioned entity’s property turns up within Canadian jurisdiction, SEMA requires Canada to freeze it. Canada has not frozen these funds for one reason only: until Division 18, it lacked the power to compel institutions to identify them. That power now exists, so Canada can now meet the obligation. Confirming the precise amount also lays the foundation for everything that follows, because Canada cannot act on, or negotiate over, assets it has not identified.

2. It adds protection for Ukraine. 
   Today the funds rest on EU sanctions alone. If the EU lifts those sanctions or a settlement is reached with Russia, the funds could flow back to Russia without Canada having any say. An independent Canadian freeze creates a “double lock” and ensures Canadian legal sovereignty over subject Russian assets. This means no funds in Canada can leave without Canadian approval, regardless of what the EU decides. This safeguards assets that can support Ukraine and protects the windfall profits already servicing Ukraine’s Extraordinary Revenue Acceleration (ERA) loans.

3. It gives Canada a seat at the table. 
   Canada holds roughly 7 percent of the frozen assets Euroclear manages, but without confirmed figures or an independent freeze, it has little leverage. Identifying and freezing the funds gives Canada a real say in what ultimately happens to them and ensures none return to Russia without Canadian agreement.

How to use the new tools to find, segregate, and freeze the funds

Division 18 gives the Government the authority to require disclosure, but the Government must now activate it. The Governor in Council needs to pass regulations under the new SEMA provisions directing Canadian financial institutions to report the foreign property in their possession or control. Until the Government enacts those regulations, the law remains an unused tool. The regulations, and any accompanying communications, should do the following:

1. Name the target explicitly. 
   The regulations should state plainly that the disclosure covers assets the RCB, the NWF, and the Russian Ministry of Finance hold indirectly through Euroclear or any other intermediary.

2. Direct financial institutions to look through the correspondent relationship. 
   Canadian financial institutions need to put a straightforward question to Euroclear: of the funds in Euroclear’s Canadian-dollar accounts, how much of each account does the RCB, the NWF, or the Russian Ministry of Finance ultimately own or control?

3. Prepare the licensing framework in advance. 
   Under standard Canadian sanctions practice, if an institution suspects that funds in an account belong to a sanctioned entity and cannot confirm otherwise, it will freeze the account. A blanket freeze of Euroclear’s Canadian accounts would disrupt both Euroclear and the windfall profits now servicing Ukraine’s ERA loans. The Government should therefore issue licenses alongside the disclosure regulations, allowing institutions to keep servicing Euroclear’s accounts provided they segregate the sanctioned Russian state funds into separate, clearly identified accounts.

4. Require ongoing reporting. 
   The initial disclosure should not be a one-time exercise. The regulations should set a periodic reporting obligation, so the Government keeps a current picture of the amounts held, any change in their composition, and any profits the sanctioned funds generate within Canadian institutions.

In practical terms, the Government needs two steps: 

1. Enact the disclosure regulations to identify the funds;

2. Issue licenses that let institutions segregate the funds and direct the interest they earn to keep funding the ERA loans, under controlled, transparent conditions subject to Canadian oversight.

What segregation will not do

Finding, segregating, and freezing the CAD-denominated funds in Canadian institutions does not confiscate, transfer, or otherwise repurpose them, because it does not change their legal title. It simply lets the Government confirm whether the funds are in Canada and, if they are, add a Canadian freeze alongside existing European sanctions.

Outright transfer to a Ukraine compensation fund is a separate question. SEMA permits such a transfer, and it aligns with the stated platforms of all major Canadian political parties as of the April 2025 general election. But that step is a political decision, and it lies outside the scope of what this memo recommends.

Request

We, the undersigned, request that the Government immediately identify, segregate, and independently freeze the Russian state assets under its jurisdiction, using the legislative powers already at its disposal. Canadian law requires it. The step will safeguard funds already within Canadian jurisdiction and position Canada to play a constructive, authoritative role in any future negotiations over how to use the frozen assets to advance justice for Ukraine and its people.

Signatories

The Right Honourable Stephen J. Harper, 22nd Prime Minister of Canada, 2006-2015

The Honourable Allan Rock, Canadian Ambassador to the United Nations, 2004-2006 and Minister of Justice, 1993-1997

The Honourable Lloyd Axworthy, Minister of Foreign Affairs, 1996-2000

The Honourable Jason Kenney, 18^th Premier of Alberta, 2019-2022; Minister of National Defence, 2015 & Minister of Citizenship, Immigration and Multiculturalism, 2008-2013.

The Honourable Chris Alexander, Minister of Citizenship and Immigration, 2013-2015 and Canadian Ambassador to Afghanistan, 2003-2005

Artis Pabriks, Deputy Prime Minister & Minister of Defence, 2019-2022; Minister of Defence, 2010-2014; Minister of Foreign Affairs, 2004-2007, Republic of Latvia

Gabrielius Landsbergis, Minister for Foreign Affairs, 2020-2024, Republic of Lithuania

Shuvaloy Majumdar, MP for Calgary Heritage & Vice-Chair, Subcommittee on International Human Rights

Heather McPherson, MP for Edmonton Strathcona; NDP House Leader & Critic for Foreign Affairs and International Development 

The Honourable Donna Dasko, retired Senator for Ontario

The Honourable Dr. Stanley Kutcher, retired Senator for Nova Scotia

The Honourable Ratna Omidvar, C.M., O.On., retired Senator for Ontario

Bill Browder, CEO Hermitage Capital Management & Head of the Global Magnitsky Justice Campaign

Jamison Firestone, Co-Founder, Global Magnitsky Justice Campaign

Aaron Gasch Burnett, Senior Security Policy Fellow, European Resilience Initiative Center

Yuliya Ziskina, Senior Legal Fellow, Razom for Ukraine

Marcus Kolga, Senior Fellow, Macdonald-Laurier Institute

Kyle Matthews, Executive Director, Montreal Institute for Global Security

Gila Cotler, CEO, Raoul Wallenberg Centre for Human Rights

Brandon Silver, international human rights lawyer & Director of Policy and Projects, RWCHR

Fen Osler Hampson, President, World Refugee & Migration Council

Philip Zelikow, 27th Counselor of the United States Department of State (2005-2007), Botha-Chan Senior Fellow, Hoover Institution, Stanford University

Elizabeth Anderson, Director of Operations to Canada’s Minister of Foreign Affairs, 2023-2024

Yaroslav Baran, Co-founder, Pendulum Group; Chair, Parliamentary Centre; Founding Board Chair, Canada-Ukraine Foundation International

Bob Onyschuk, KC, JD, Chair Emeritus Canada-Ukraine Foundation

James C. Temerty, Chairman of Temerty Foundation; Founder, Northland Power

Balkan Devlen, Senior Fellow, Macdonald-Laurier Institute & Montreal Institute for Global Security

Olena Halushka, Co-Founder, International Center for Ukrainian Victory & Board Member, Anti-corruption Action Center

Timothy Ash, Senior Sovereign Strategist, RBC Bluebay Asset Management & Associate Fellow, Chatham House

Katherine Vellinga, Board of Directors, Canada-Ukraine Chamber of Commerce

Michael Cholod, Executive Director, Peace Coalition Foundation

Sergej Sumlenny, Founder and Managing Director, European Resilience Initiative Center

Related Articles

“Canada must act to ‘double-freeze’ Russian assets”. Bill Browder, Marcus Kolga and Aaron Gasch Burnett (Senior Security Policy Fellow, ERIC) 

“Canada can send a clear message to Russia by making one bold move”. Senator Donna Dasko and Aaron Gasch Burnett (Senior Security Policy Fellow, ERIC)