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Title page 1

Contents 5

Abstract 4

Résumé 4

Introduction 6

CSDs maintain the ultimate record of securities ownership 8

Segregated vs omnibus accounts 9

Fragmentation of the EU market 14

Horizontal and vertical integration 16

Eurosystem's initiatives to harmonize post-trade processes 19

ICSDs and sanctions enforcement 22

ICSDs and foreign reserve holdings 22

Clearstream and the Central Bank of Iran: A case of sanctions circumvention 24

ICSDs are essential players in the eurobond markets 24

Russian assets reflected on Euroclear's balance sheet 26

The use of windfall contribution to support Ukraine 27

EU response to Russia's freezing and confiscation of Western assets 29

Seizing Russian assets 29

Additional risks and challenges 31

Building Asia's First ICSD 31

Cyberattacks 31

Distributed Ledger Technology 32

Conclusions 34

References 35

Tables 11

Table 1. Number of omnibus and individual accounts 11

Table 2. Vertical and horizontal integration of securities trading, clearing, and settlement in Europe (selected major players) 16

Table 3. Impact of Russian sanctions on Euroclear Holding's accounts 26

Table 4. Calculation of windfall contribution for 2024 28

Figures 10

Figure 1. Direct and indirect account holding models 10

Figure 2. Number of participants in the largest CSDs in the EU 10

Figure 3. Value of securities managed by individual CSD 15

Figure 4. Value of deliveries managed by individual CSD 15