The ladder from freezing to taking
The most decisive weapon in 21st-century geopolitics is not a missile system — it is access to a payment rail. What states may do with an adversary's money runs on a three-rung ladder: freeze, use, take.
The most decisive coercive tool in 21st-century geopolitics is often not a weapons system. It is access to the financial network. That sounds dramatic — it is — and the question it forces on policymakers, compliance teams and investors alike is blunt: who controls the chokepoints?
This is the first essay in a three-part series on what states may do with an adversary’s money — the debate I followed as a six-part LinkedIn series in early 2026, rebuilt here with full sourcing and the benefit of what has happened since.
Three concepts carry everything that follows
Financial interdependence is our shared cross-border reliance on banks, custodians, clearinghouses and settlement systems. Weaponized interdependence — Farrell and Newman’s term, and the intellectual anchor of this series — is the strategic exploitation of network centrality to coerce, surveil, or exclude: states that sit on hubs can watch everything that flows through them (the panopticon effect) or cut adversaries off entirely (the chokepoint effect). And the asset-control ladder is the practical escalation spectrum this series climbs rung by rung: freeze → use → take.
Modern sanctions do not require troops. They require legal authority over the nodes where capital converges. (Yes — enforcement ultimately still rests on state power in the old sense. But the instrument of first resort has changed.)
What the EU has actually done — not merely debated
Commentary on frozen Russian assets often blurs what is proposed with what is law. The implemented record, as of early 2026, is specific:
Europe holds roughly €210 billion in immobilised Russian sovereign and central-bank assets, of which about €185 billion sits at a single institution — Euroclear, the Brussels central securities depository. Immobilisation means the assets cannot move; ownership formally remains with Russia. That is rung one.
Rung two is where the EU broke new ground. Council Regulation (EU) 2024/1469 created a legal mechanism to capture the extraordinary revenues — the windfall profits — that the immobilised principal generates, and in July 2024 the Commission confirmed the first €1.5 billion transfer of such proceeds for Ukraine. Profits are being used; principal is not. The G7’s ~$50 billion ERA loan architecture is built on the same logic: lend against future profits rather than touch the underlying assets.
In December 2025 the Council escalated within rung one: it prohibited transfers of immobilised Central Bank of Russia assets back to Russia, converting a sanctions regime that needed unanimous renewal every six months into an effectively indefinite immobilisation — a legal answer to a political veto risk.
And the counterparty is no longer passive: in December 2025 the Russian central bank sued Euroclear in a Moscow court, reportedly seeking some $230 billion in damages. Retaliation, long cited as a theoretical cost of climbing the ladder, now has a docket number.
Why the ladder matters
Each rung is legally and politically distinct. Freezing restricts dealing while title stays with the target — well-established sanctions practice. Using extracts value (profits, collateral) without taking ownership — the EU’s innovation, deliberately built to limit the precedent shock. Taking — confiscation of principal, a transfer of title — is the rung no major custodial jurisdiction has yet climbed with sovereign central-bank assets, because that is where sovereign immunity, reserve-currency credibility and the rule-of-law brand of the confiscating jurisdiction all collide.
Push too hard, and you undermine the very trust that makes your infrastructure a chokepoint worth controlling. Push too little, and adversaries learn that immobilisation is a parking ticket. Neither pole is comfortable, and the honest position — which I hold — is that the right limiting principle is genuinely unsettled.
Part 2 examines that limiting principle: the legal boundary between sovereign immunity and countermeasures, and the precise anatomy of what “seizure” means in United States law. Part 3 takes the ladder somewhere stranger: what happens when the asset is not an entry at Euroclear but a private key — the Venezuela crypto question.
Sources
Farrell & Newman, “Weaponized Interdependence”, International Security 44:1 (2019) · Council Regulation (EU) 2024/1469 · European Commission, first €1.5bn transfer, 26 Jul 2024 · Council, prohibition of transfers back to Russia, 12 Dec 2025 · Reuters explainer on amounts and Euroclear concentration · G7 ERA loans statement · Moscow Times on CBR suit against Euroclear, Dec 2025 · Companion concepts: Weaponized Interdependence, The Off-Chain Gap → Amounts are approximate and framing-dependent; all figures re-verified 30 Jul 2026.