Asset freezes in Belgium — notifying the Treasury

In Belgium, frozen funds are reported to the Treasury, not to the NBB and not to CTIF-CFI. The General Administration of the Treasury, part of FPS Finance, is the competent authority for financial sanctions. It receives notifications of frozen accounts, answers homonym checks, grants derogations and authorises the release of anything frozen. The NBB supervises whether a payment or e-money institution has a working sanctions control system. CTIF-CFI receives suspicion reports. Those are three different tracks, and firms that merge them file in the wrong place. This guide covers the legal basis, what the Treasury expects to receive and how, the homonym and derogation procedures, the Iran transfer regime restored in 2025, and four worked scenarios.

1. Three legal layers

Belgium applies financial sanctions from three sources. EU regulations apply directly, because they have direct effect in every member state. National law adds the penalties and the implementing powers. A separate national list covers terrorism suspects designated by Belgium alone.

The national list comes from UN Security Council Resolution 1373 (2001). The National Security Council draws it up on the basis of an assessment by the Coordination Unit for Threat Analysis (OCAM/OCAD), after consulting the support services and the judicial authorities. The Treasury publishes it as an XLSX file. It is not part of the EU consolidated list. A firm that screens only against EU lists misses it. The Treasury also maintains its own consolidated list, which combines national, EU and UN designations, but it states that only the Official Journal of the EU is authentic for EU measures.

2. What you notify, and how

For the national list, the Treasury states the obligation plainly. Every person must freeze the funds of listed persons and entities, and must not make funds available to them, directly or indirectly. The freeze overrides contracts. It covers funds owned by a listed person and funds in their possession or under their control. Every person must also pass to the Treasury any information that would help apply the measure, and must cooperate when the Treasury checks it.

The Treasury lists what that information includes:

• frozen accounts: the account holder, the account number and the value of the frozen funds;
• data on the identity of listed persons or entities;
• incoming transfers that credit a frozen account;
• attempts by customers or others to make funds or economic resources available to a listed person without authorisation;
• information indicating that freezing measures are being circumvented.

The EU regulations carry their own reporting duties to the competent authority of the member state. In Regulation (EU) No 269/2014, Article 8 requires natural and legal persons to supply immediately any information that would facilitate compliance, such as accounts frozen, and Article 7 allows a frozen account to receive credits only if the additions are also frozen and the competent authority is informed without delay. For Belgium, that authority is the Treasury.

The channel is simple. Information goes by e-mail to quesfinvragen.tf@minfin.fed.be, or by post to the Minister of Finance, c/o General Administration of the Treasury, Avenue des Arts 30, 1040 Brussels. There is no portal and no general notification form. The exception is the Iran transfer regime, which has its own XLSX form (section 5).

Timing follows the same logic as elsewhere in the EU. The Treasury says the implementation of embargoes and asset freezes must be done without delay as soon as they enter into force, and that it is an obligation of result. When the authorities ask for information after a new measure, the notification is mandatory. The Treasury recommends notifying negative results as well, meaning a confirmation that you hold nothing for the persons concerned.

3. Treasury, NBB, CTIF-CFI: who does what

The split matters because each authority has a different job, and none of them forwards your report to the others.

The Article 8 duty is narrower than people assume. The Treasury explains that the AML law’s control-system obligation targets sanctions regimes against terrorism and against proliferation of weapons of mass destruction, such as the national list, the ISIL/Al-Qaida regime and the North Korea regime. The freeze obligations of every other regime, including Russia, still bind you directly under the EU regulations. In practice, firms run one screening system for all regimes.

4. Homonyms and derogations

The Treasury checks whether a customer is the person covered by a freezing measure when the name is the same or almost the same. Its procedure has three steps:

1. The institution informs the Treasury that it holds funds for a person or entity named in a sanctions regime and asks it to check whether this is the designated person.
2. It sends all the information it holds that allows the check, such as a copy of the identity card or passport, and the number of the regulation or decision in which the name appears.
3. It sends the file to quesfinvragen.tf@minfin.fed.be.

Derogations work on a complete-file basis. The Treasury will only examine a request when every required item is supported by documents, with certified translations into a national language or English. Incomplete requests are closed without review. A request to release or transfer frozen funds must state:

• the regulation and article relied on;
• the debtor or ordering party, and the creditor or beneficiary;
• the amount and currency;
• the reason for the request;
• the banks and institutions involved;
• the date of the contract or obligation under which the payment is due;
• supporting documents, such as an invoice, a mandate, an identity document or the agreement.

Requests go to the same e-mail address. Frozen assets in Belgium can never be released without the Treasury’s authorisation. Processing time depends on the complexity of the request, and the Treasury gives no fixed deadline.

5. Iran: the transfer regime is back

On 27 September 2025 the UN Security Council sanctions against Iran were restored under the “snapback” mechanism. At EU level, Regulation (EU) No 267/2012 was reactivated and amended by Regulations (EU) 2025/1975, 2025/1980 and 2025/1982. The Treasury lists the parts that fall within its competence:

Linked transactions count together. Several transfers from or to the same financial institution, or from or to the same Iranian person, are treated as linked and must be reported if together they meet the thresholds (Art. 30bis(2)). A payment firm therefore needs aggregation logic, not a per-payment check.

6. Four worked scenarios

Scenario one — an incoming credit to a frozen account. A Belgian e-money institution froze a customer’s wallet after the customer was added to the Annex I list of Regulation (EU) No 269/2014. A EUR 2,400 SEPA credit arrives from a third party. Rule: Article 7 of the regulation allows the credit if it is also frozen and the competent authority is informed without delay. What compliance does: books the credit to the frozen balance and e-mails the Treasury with the account, the amount, the payer and the date. Outcome: the credit is lawful because it was frozen and notified. Paying it out, or returning it to the payer without authorisation, would not be.

Scenario two — a rejected outbound payment. A customer of a Belgian payment institution orders EUR 5,000 to a company that is on the Belgian national list but not on any EU list. Screening against the national list XLSX stops it. Rule: the national freeze under the Royal Decree of 28 December 2006, and the duty to pass on attempts to make funds available. What compliance does: rejects the payment, notifies the Treasury with the payer, the payee and the amount, and reviews the customer’s other counterparties. If the facts suggest terrorist financing, it also files with CTIF-CFI. Outcome: two separate filings on two separate legal bases. A firm screening only the EU consolidated list would have executed the payment.

Scenario three — a homonym. A new customer’s name is identical to a listed person’s. Date of birth and nationality differ, but the customer’s passport was issued in the listed person’s country. Rule: the Treasury’s homonym procedure. What the analyst does: holds the account, records the comparison, and because doubt remains, sends the Treasury the passport copy and the number of the regulation that names the listed person. Outcome: the account stays on hold until the Treasury answers. The analyst keeps the full file for supervision.

Scenario four — Iran thresholds. A business customer sends three transfers of EUR 9,000, EUR 8,000 and EUR 7,500 in one month to the same Iranian company, each below the notification threshold. Rule: Art. 30bis(2) of Regulation (EU) No 267/2012 on linked transactions. What compliance does: aggregates the three transfers to EUR 24,500 and files the Treasury’s Iran form for the linked series. A fourth transfer that would bring the total above EUR 40,000 is held until authorisation is granted. Outcome: the firm complies at series level. A per-payment rule would have missed all four.

7. FAQ

8. What to do, today

• Add the Belgian national list XLSX to your screening sources, with an owner who checks it after every Royal Decree amending the 2006 decree.
• Write the Treasury address, quesfinvragen.tf@minfin.fed.be, into the freeze procedure. Remove any step that routes freeze notifications to the NBB or to CTIF-CFI by default.
• Make rejected payments and incoming credits to frozen accounts generate a Treasury notification, not only blocked balances.
• Build a homonym file template: identifiers compared, the document copy and the regulation number. That is what the Treasury asks for.
• For Iran, add aggregation by counterparty and by counterparty institution, with the EUR 10,000 notification and EUR 40,000 authorisation thresholds.
• Keep a log of every notification and Treasury reply. The NBB will ask for it when it reviews your Article 8 control system.

Related: EU asset-freeze reporting — Article 8 · CTIF-CFI and goAML in Belgium · NBB periodic AML questionnaire