The West is struggling to follow through on sanctions to freeze Russian money inside the EU. Conflicting reports on how much oligarch cash has been frozen emerged on March 9, while recently the EU legal department said it could only identify about $37bn of the $250bn of Central Bank of Russia (CBR) reserves thought to be in EU accounts.

The West has frozen over $58bn of assets belonging to oligarchs and other Russian nationals in the past year, the Russian Elites, Proxies, and Oligarchs (REPO) task force said in a statement on March 9. However, other reports put the number much lower at $20bn.

The task force has been set up as a multilateral body of Western countries to track down Russian money and assets hidden in the West, with powers to seize any properties associated with Russians under sanctions.

However, according to other unspecified EU authorities, the bloc has so far only frozen €20.9bn ($22bn) in assets, despite multiple rounds of sanctions, Bloomberg reported the same day. And that number is not growing. Back in October, the bloc reported that some €17.4bn had been frozen.

Belgium and Luxembourg have immobilised billions, but other member states have frozen sums that barely break out of six digits, with Greece saying it has frozen only €212,201 and Malta reporting €222,470, according to the latest numbers, seen by Bloomberg.

In February, Swiss bank Credit Suisse announced it had frozen CHF17.6bn ($19bn) worth of Russian oligarch assets frozen on its accounts, a figure estimated to be about one third of all the Russian assets registered in Switzerland (CHF46.1bn or almost $50bn), although Switzerland is not in the EU.

Experts believe that the amount of private money in Europe is an order of magnitude higher and most of it remains untouched. The London homes of just the top five oligarchs are worth more than $1bn alone. In general, Russia’s total foreign direct investment (FDI) stock in the EU was estimated to be €136bn, Bloomberg reports.

REPO reports more success. Since the start of Russia's special military operation in Ukraine, the task force "has leveraged extensive multilateral co-ordination to exert unprecedented pressure on sanctioned Russians," REPO said in the statement.

Members of REPO have successfully blocked or frozen more than $58bn worth of sanctioned Russians' assets and heavily restricted them from the international financial system.

Amongst the targets are real estate, luxury yachts, aircraft and other assets associated with the oligarchs and others on the Specially Designated Nationals and Blocked Persons (SDN) List.

REPO said that in addition to freezing assets, the task force had also affected the first forfeiture of assets of a sanctioned Russian, but the sum is a paltry $5.4mn, which has been sent to Ukraine as foreign assistance.

The almost negligible amount of Russian assets that have not only been frozen but also seized, transferring their ownership to the EU authorities, highlights the legal difficulties of taking procession of frozen assets. Under EU law assets can easily be frozen, but they can only be seized if there is a criminal conviction of the owner. In the case of state-owned assets, those can only be legally seized if the two countries are officially at war.

There have been constant calls for the reported $300bn of CBR reserves frozen by the Western sanctions in the first days of the war. However, in the last month the EU legal authorities admitted that they can’t find most of Russia’s $300bn of frozen reserves. Only a total of just over $37bn had been identified and frozen. The EU is current putting together a centralised registry of frozen Russian assets so countries can co-ordinate their actions better.

The EU’s executive spokesman, Christian Wigand, admitted to Bloomberg that the EU relies on information provided by members states and that the frequency of the updates provided by different governments is uneven. In the tenth package of sanctions EU members wanted to introduce some Union-wide obligatory reporting requirements on banks but resisted efforts to impose fines on those that don’t comply.

The REPO task force is composed of representatives from various countries, including the US Treasury and Justice secretaries, as well as representatives from Australia, Canada, France, Germany, Italy, Japan, the UK and the European Commission.