A query by Marcel Emmerich, the Greens’ parliamentary spokesperson for interior affairs, to the German Federal Ministry of Finance revealed that the total value of private assets frozen in connection with the Ukraine war has dropped sharply. In 2025 the figure was still about €2.9 billion, compared with nearly €3.3 billion the year before. In 2023 the frozen Russian assets in Germany had peaked at almost €4.4 billion. The Federal Ministry of Finance confirmed these figures in a statement to the FAZ (Monday edition), citing Emmerich’s request for the data.
The freezing mechanism is based on an EU regulation adopted in 2014 after Russia’s annexation of Crimea. The regulation allows sanctions to be imposed on individuals deemed responsible for actions that threaten Ukraine’s territorial integrity and independence. The regulation has been updated repeatedly, most recently in December 2025, to reflect the broad sanctions imposed after Russia’s full‑scale invasion in February 2022. Prior to the 2022 escalation, the amount of frozen Russian assets in Germany was a mere €342 000, before the figures exploded that year.
The Ministry offers two explanations for the recent decline. First, the assets are subject to valuation fluctuations. More decisively, people are being removed from the sanctions list after successfully challenging their inclusion in court. EU court rulings over the past few years have suggested that, in some instances, the reasoning for listing individuals was questionable-particularly regarding whether the listed persons had actually supported actions undermining Ukraine’s sovereignty.
“Strengthening the enforcement of sanctions remains a top priority for the federal government” the Ministry said. As part of that effort, it is evaluating the sanctions‑enforcement laws enacted in 2022 (Sanctions Enforcement Act I and II). The Ministry is currently assessing whether the relevant legislation needs to be amended to make enforcement more effective.
Emmerich told the FAZ that the decline in frozen assets is not a trivial matter but a warning signal. He warned that lax enforcement could make the sanctions regime less effective and called for a rigorous approach to sanctions enforcement, including tougher measures against circumvention.
