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How "blocked" stock seeped into the market while the central bank insisted it was impossible

When a large American bank was selling a blocked stake in Sberbank at a discount of about 70%, the Bank of Russia's public position sounded reassuring: such securities cannot create an overhang on the market, because by law they sit in segregated accounting and do not enter free circulation. This was the load-bearing thesis of the whole construction "the effect of blocked assets is insignificant".

Two years later the FSB arrested the head of the company that was the official operator of the exchange of blocked assets at the central bank itself, and the regulator for the first time revoked a depositary licence for the very action that was considered impossible: lifting segregated accounting by a backdated entry. That is, the wall that the central bank pointed to as a guarantee turned out to be possible to bring down, and from inside its own accounting system at that. This article by Enhanced Investments is about the gap between the guarantee and reality, and about where in this market the line between the norm and crime runs.

First the key: "blocked stock" is three different contours, and only one of them is criminal

Without this distinction the argument is meaningless. Under "dumping of blocked stock" three channels of fundamentally different legality are mixed:

This removes the apparent contradiction "the effect is small, but a criminal case for billions": almost the entire volume is insignificant and legal; what is criminal is a narrow black edge. They cannot be confused in either direction.

A whole industry works with blocked stock, and its legal part is large

It is important to dispel the false impression that blocked stock is an underground business of a couple of players. On the contrary: almost the entire large brokerage and asset management business works with it legally.

The economics of the legal contour is transparent: a broker buys a liquid blocked security at a discount of 45-50%, accumulates it in a fund, and the sale takes place at a discount that grew to 60% in 2024. The deals require permissions from three parties at once: OFAC, the Belgian Ministry of Finance and the Russian subcommission. According to media reports, the large buyer of the current wave is a long-standing foreign investor, the fund Prosperity Capital Management, and not any particular Russian broker. This is a normal, licensed market, and it cannot be confused with "backdating".

The whole central bank guarantee rested on one control: segregated accounting

What did the thesis "there will be no overhang" stand on? On segregated accounting: securities of non-residents from "unfriendly" jurisdictions are physically segregated in the depositary system and should not mix with free circulation. The regulator's public logic was direct:

The Sberbank stake sold by JPMorgan at a discount of about 70% was cited as an illustration: since the security is by law on a separate account, there is no risk of an "overhang". Flawless, on one condition: that segregated accounting cannot be lifted.

Exactly one technique is illegal, and any depositary can lift segregated accounting

Neither ZPIFs, nor over-the-counter trading, nor exchange under the Decree make this market criminal. Exactly one thing is illegal: lifting segregated accounting by a backdated entry, after which the security loses its "brand" and enters the order book at the full price. According to a reconstruction of the mechanics:

The key point: any depositary can technically do this; the problem is the very possibility of rewriting the accounting history, not a particular company. The only publicly documented case is the revocation of Alor+'s depositary licence on 26 June 2026, with the central bank's wording about "backdated entries" and violation of anti-sanctions regulation. An honest caveat matters here: this episode became visible because the regulator named it, not because the main volume went through it. What share any single depositary has in this channel, nobody counts publicly; there is no basis to believe that the "dumping" went mainly through one player. Rather the opposite: with dozens of depositaries and an enormous mass of blocked securities, the channel is by definition distributed.

While the wall was being broken, the central bank removed for half a year the instrument that measured it

The thesis "the effect is insignificant" relied on the "Financial Markets Risk Reviews". But it was precisely there that from July to November 2024 the breakdown of exchange flows by participant category, the one from which non-residents are visible, disappeared. It was last published for June 2024 and returned only on 6 February 2025. In the "blindness" window the text named sellers differently: in August, "individuals sold RUB 17.9 bn", in September, "banks not related to SZKO".

According to a reconstruction based on infographics previously published by the central bank, in July 2024 net sales by non-residents and their "subsidiaries" through trust management reached about RUB 50 bn, the maximum since February 2022. And on an annual basis retail investors were designated the largest net sellers of shares, RUB 113.9 bn for 2024. A picture in which non-resident flows are not shown for half a year and retail is made the "culprit" is the very instrument by which "insignificance" was measured.

One and the same operator ran the central bank's official exchange and the criminal scheme

The Government Commission appointed the Voronezh Investment Chamber of Alexey Sedushkin as the operator of the white exchange under Decree No. 844 in March 2024. According to media reports, Sedushkin, a native of Otkritie bank, bought this broker from a Voronezh developer in March 2022, right after the start of the sanctions wave, and took on about 70,000 clients, including those abandoned by Otkritie Broker. One of the publications describes his role directly: he helped businessmen "on both sides" circumvent sanctions.

In May 2026 the same Sedushkin was arrested in a case of fraud on an especially large scale. The FSB estimates the damage at more than RUB 7 bn; a number of publications cite the volume of alleged transactions as RUB 10.64 bn, exactly the amount of the entire official exchange under Decree No. 844 for 2024. Such a coincidence of amounts shows how closely the official and criminal contours are intertwined in this case: the exchange was run by one operator, under the control of the central bank and the Ministry of Finance.

The other end of the scheme: a re-badged "Zerich" that moved to Cyprus

The counterparty was Cyprus-based Mind Money Limited of Yulia Khandoshko. According to the investigation and open sources, it is the successor of "Zerich", Zerich Securities Ltd. from the Zerich Capital Management group, which was rebranded in 2021 (CySEC licence 115/10). Mind Money, according to the investigators, helped obtain unblocking licences from European regulators. According to one version in Kommersant, the actual fraud began next: the investor was told that assets had been credited but was not given access, and the securities could be "withheld, redirected or stolen" under the guise of technical procedures.

The chronology of the finale is telling: on 23 June 2026 the Cypriot regulator CySEC suspended Mind Money's licence, and on 26 June the central bank revoked Alor's depositary licence. The coordinated crackdown at the end of June closed both ends of the channel at once.

The "blind spot": how much leaked and through whom, nobody counts

The most uncomfortable part concerns scale. According to the Moscow Exchange's estimate, up to 60% of the free float of Russian shares has settled on type "C" accounts. How much of this has been "re-coloured" and entered the order book, and through which depositaries exactly, has not been publicly calculated. The wording from the market analysis is precise: "how many more securities could be and are leaking through other depositaries, nobody counts publicly. This is the blind spot". That is why naming one "main culprit" is incorrect: not only the volume is unknown, but also its distribution.

The opacity is systemic. The central bank last disclosed balances on type "C" accounts in March 2023 (about RUB 500 bn), after which it stopped. Meanwhile foreign investors' assets in accounts in Russia reached a record RUB 2.6 trn by the first quarter of 2026. The guarantee "there can be no overhang" cannot be verified where the key figures are not published.

A twist: a significant part of the "non-residents" are Russians from abroad

And the cherry that turns the moral frame over. According to analysts' estimates, more than a third of operations by "foreigners" on these accounts go through foreign accounts controlled by Russian beneficiaries. That is, a noticeable share of the "non-resident overhang" is domestic money in a foreign wrapper. In this light, part of the "help to stranded non-residents" turns into a channel in which insiders, with access to the discount, shift securities onto Russian retail investors at the full price. The discount goes to those admitted, the full price to retail. The question is not about sanctions but about who is on the list.

The central bank's mandate is not equal profit but equal rules and disclosure; it was disclosure that was squeezed

The Bank of Russia has no obligation to equalise the benefit from the discount: it is distributed by the executive branch through the subcommission, and complaints about "unequal conditions" in the grey contour are addressed there, not to the regulator. But the central bank has a direct mandate (the central bank law, Article 75 of the Constitution, the law on countering market manipulation): protecting investors' rights, supervising depositary activity, countering unfair practices and equal access to information. A "backdated entry" and the release of a hidden overhang onto retail fall under it directly.

The main paradox: the only thing that lies entirely within the central bank's competence is transparency. And it was cut back for the key half-year, by removing the flow chart and ceasing to disclose type "C" balances. The regulator has intervention tools: in February 2026 it blocked the offer by Nedvizhimye Aktivy to buy back shares of PIK, and in the summer it revoked a depositary's licence. The question is not whether tools exist, but how timely they are, and that the black edge was closed only when the security services took it on.

In the world this wall cannot be broken technically, and that is the main difference

The secondary market in frozen and defaulted claims is legal everywhere, but wrapped in licensing and disclosure. Any operation with frozen Russian assets in the West requires an individual permission (OFAC, EU derogations), and the infrastructure of Euroclear and Clearstream keeps securities immobilised and does not let their accounting history be rewritten. There the analogue of segregated accounting cannot be lifted retroactively, and it is precisely this possibility that is the root of the black contour. The IOSCO principles guarantee not equal enrichment but equal rules, transparency and investor protection. The Russian difference is not the existence of a discount (it is economically justified), but closed access to it plus the technical possibility of "re-colouring" inside the accounting system.

Conclusion: the "insignificant effect" was not a measurement but the absence of one

The story forms a line. The regulator pointed to segregated accounting as a wall guaranteeing safety. It turned out that this wall could be removed by a single backdated entry, and technically this is available to any depositary, while only one episode out of an unknown number is publicly known. The instrument that would have shown the leak was removed for half a year, and balances of blocked money ceased to be published. The official exchange and the criminal scheme were run by one operator; the resolution came only through the FSB and CySEC.

The answer to the original question. The central bank has no mandate to equalise profit from the discount. But it has a direct mandate for equal rules and disclosure. And the one thing that was entirely in its hands, the transparency of flows, turned out to be exactly what was squeezed for the key months. The "insignificant effect" rested not on the absence of a leak but on the fact that it stopped being measured.

Sources

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