# ANALYSIS: The ICC, Russia's central bank, and the reclassification of financial war crimes

> On June 27, 2026, Euromaidan Press published an interview revealing the full scope of a complaint filed before the International Criminal Court in July 2025 by LexCollective (LexCo), a global coalition of lawyers, analysts, and investigators. This formal communication, submitted to the ICC Prosecutor's Office, names the governor of the Russian Central Bank, Russian Finance Mini

- Author: Maxime Marquette
- Publisher: MadMax (https://mad-max.co)
- Section: Analysis
- Published: 2026-06-29
- Canonical URL: https://mad-max.co/en/article/analyse-la-cpi-la-banque-centrale-russe-et-la-requalification-des-crimes-financi

## Introduction: When bankers become war crimes suspects

### A complaint that rewrites the rules of international accountability

On **June 27, 2026**, **Euromaidan Press** published an interview revealing the full scope of a complaint filed before the **International Criminal Court** in **July 2025** by **LexCollective** (LexCo), a global coalition of lawyers, analysts, and investigators. This formal communication, submitted to the ICC Prosecutor's Office, names the governor of the **Russian Central Bank**, Russian Finance Minister **Anton Siluanov**, and the leaders of three Russian banks operating in occupied Ukrainian territories as accomplices in war crimes and crimes against humanity. This is not a complaint against the Russian army. It is a complaint against the financiers of the occupation.

The logic is radical and unprecedented: the bankers, accountants, and financial technocrats who architected the financial occupation of **Ukraine** — the forced imposition of the ruble, the seizure of Ukrainian assets, medical care conditioned on a Russian passport — are just as responsible for civilian suffering as the soldiers who fired the missiles. **LexCo** states that this is the first such complaint to its knowledge. If it succeeds, it will fundamentally transform the notion of international criminal accountability.

### ICC judges versus Trump: a collision of jurisdictions

Paradoxically, at the very moment the **ICC** receives this historic complaint against the Russian financiers, three of its judges — **Kimberly Prost** (Canada), **Solomy Balungi Bossa** (Uganda), and **Reine Sophie Alini-Gou** (Benin) — filed on **June 25, 2026** a complaint before an American federal court in **Manhattan** against the **Trump** administration. These judges contest the sanctions **Washington** imposed on them, which prevent them from accessing their bank cards, accounts, online platforms, and in some cases their health insurance. They describe these sanctions as "financial death sentences."

The judges argue that these sanctions violate the **IEEPA** (International Emergency Economic Powers Act) and constitute extrajudicial pressure designed to intimidate them and influence **ICC** decisions in cases involving American and Israeli nationals. The **Trump** administration imposed these sanctions in response to the ICC's investigation into allegations of war crimes in **Afghanistan** and at **Gaza**. The collision between international judicial sovereignty and American coercive power is now explicit.

*Here is the surreal situation of the ICC in June 2026: its judges are simultaneously pursuing the Russian financiers of the Ukrainian occupation AND suing the Trump administration for trying to silence them. The institution is under pressure from two opposite directions. Its survival as a credible institution depends on its ability to hold both fronts at once. This is an existential test.*

## LexCollective: anatomy of an unprecedented legal strategy

### Who is LexCo and what is its theory of the case?

**LexCollective** is an international coalition of lawyers and investigators specializing in criminal accountability for mass crimes. Their theory in the Ukrainian case is as simple as it is bold: Russian bankers are not neutral technocrats. They provided the financial infrastructure, the tactics, and the resources that make the permanent occupation of Ukrainian territories possible. Without the **Russian Central Bank** to authorize and regulate banks in the occupied zones, without the financial institutions that imposed the ruble and conditioned access to services on a Russian passport, the occupation could not sustain itself.

**LexCo** draws on the precedent of the **Nuremberg** trials — specifically the case against **Walther Funk**, Minister of Economics and head of the **Reichsbank**, convicted for his role in financing the concentration camps, exploiting forced labor, and storing property stolen from victims. The parallel is not perfect — the circumstances differ — but it establishes that financial actors can be held criminally responsible for their role in mass atrocities.

### The fieldwork behind the complaint

The strength of **LexCo**'s complaint is its documented factual base. The team conducted interviews with people who lived under occupation in the oblasts of **Kherson**, **Zaporizhzhia**, and in the territories occupied since **2014** (**Crimea**, **LNR**, **DNR**). A 41-year-old woman from **Kherson**, interviewed in **July 2022**, testified: without a phone connection, without a personal SMS verification code, it was impossible to access Ukrainian banking services. Her pension was being held hostage.

The pattern documented by **LexCo** follows a systematic blueprint: Russian forces seize the territory, occupation authorities cut mobile relay towers, isolating Ukrainians from the banking system. ATMs stop being restocked. To access cash, civilians must open accounts at newly installed Russian banks — which requires a Russian passport. Medical care, pensions, education — everything becomes conditional on accepting the occupier's passport. It is a form of institutional coercion designed to force annexation.

*A 41-year-old woman whose pension is being held hostage by a Russian bank until she accepts an occupier's passport. This is not a metaphor. This is not propaganda. This is a documented crime, methodical, architected from Moscow. And if the ICC accepts this logic, "I am just a technocrat" will no longer be a valid defense.*

## Elvira Nabiullina: the governor in the crosshairs

### A "technocrat" profile under scrutiny

**Elvira Nabiullina**, governor of the **Russian Central Bank** since **2013**, is often presented as one of the few competent technocrats in the **Putin** regime. An economist trained at **Moscow State University** and a former Minister of Economic Development, she navigated Western post-**2022** sanctions with some skill, maintaining a degree of stability in the Russian financial system despite the shocks. That reputation for competence is precisely what **LexCo** targets: the supposed neutrality of the technocrat masks active complicity.

According to **LexCo**'s complaint, **Nabiullina** signed the licenses authorizing Russian banks to operate in occupied Ukrainian territories. This is a regulatory decision by the Central Bank governor. Without that decision, Russian banks would have had no internal legal framework to operate in occupied Ukrainian territory. The Ukrainian **SBU** renewed its case against **Nabiullina** in **September 2024**, citing complicity in the conduct of a war of aggression.

### Siluanov and the mechanics of war financing

**Anton Siluanov**, Russia's Finance Minister since **2011**, is the second central figure targeted by the complaint. His role is twofold: on one hand, managing the finances of the Russian state at war — including determining how oil revenues and federal budgets are allocated to the war effort; on the other, overseeing fiscal policy in the occupied Ukrainian territories, where the Russian tax regime has been forcibly imposed, turning Ukrainians into taxpayers of the regime invading them.

**LexCo**'s complaint specifically cites this obligation placed on occupied Ukrainians to register as taxpayers with the Russian tax administration. This detail is fundamental to the legal strategy: it allows establishing a form of forced participation by the victims in the occupier's system — a constitutive element of the crime against humanity of persecution as defined by the **Rome Statute**.

*Siluanov signs the war budgets. Nabiullina licenses the occupation banks. These are signatures on documents — not shoot orders. But the causal chain between those signatures and the documented suffering of Ukrainian civilians is direct and provable. LexCo is right: the clean hands of technocrats are not so clean.*

## The Nuremberg precedent: the Reichsbank and Walther Funk

### The Funk case: first precedent of financial accountability for war crimes

After **World War II**, the American prosecutor at the **Nuremberg** trials secured the conviction of **Walther Funk**, who served simultaneously as Minister of Economics and president of the **Nazi Reichsbank**. **Funk** was sentenced to life in prison for his role in financing the Nazi war economy, exploiting the forced labor of deported workers, and above all for allowing the **Reichsbank** to store property stolen from **Holocaust** victims — melted gold, currency, jewelry taken from extermination camps.

This precedent is fundamental to **LexCo**: it establishes that the financial architecture of a criminal regime criminally implicates those who run it. The parallel with the current situation is not identical — Russian crimes in **Ukraine**, as serious as they are, do not reach the scale of the **Holocaust**. But the principle of financial accountability is transferable. **LexCo** is also working on a parallel case against a major French bank for complicity in the context of **Darfur**, demonstrating that this strategy is not isolated.

### The limits of the precedent and current legal challenges

Lawyers challenging **LexCo**'s theory raise several objections. First, the direct causal connection between **Nabiullina**'s financial decisions and civilian suffering is difficult to establish at the level required by international criminal law — criminal intent (mens rea) must be proven, not just impact. Second, **Russia** is not a party to the **Rome Statute** and is therefore not subject to the **ICC**'s jurisdiction in the conventional sense. The **ICC** has exercised jurisdiction on the basis of the nationality of Ukrainian victims — **Ukraine** having accepted the Court's jurisdiction in **2014** and **2015**.

These obstacles are real. But they do not invalidate the complaint — they make it difficult, not impossible. The **ICC**'s arrest warrants against **Putin** and **Maria Lvova-Belova** in **March 2023** demonstrated that the institution can act even without **Russia**'s cooperation. If arrest warrants were issued against **Nabiullina** or **Siluanov**, their travel to countries signatory to the **Rome Statute** would become impossible.

*"Russia is not party to the Rome Statute." That is the standard defensive argument. And it is technically correct. But look at what the ICC did with Putin in 2023: it issued an arrest warrant. Putin can no longer travel to the 124 member countries of the Court without risking arrest. Nabiullina and Siluanov could be next on that list. Sometimes, the law advances even when it is ignored.*

## Financial occupation: a systematic war crime

### The documented pattern in occupied territories

**LexCo**'s complaint documents a repetitive pattern in **Kherson**, **Zaporizhzhia**, **Luhansk**, **Donetsk**, and **Crimea**. In **2022** in the **Kherson** region, three banks were installed first: one from **South Ossetia**, two linked to the Russian defense sector — evidently chosen for their ability to operate in sanctioned zones. In **2023**, **2024**, and **2025**, major Russian state and private banks then penetrated these markets once the occupation regime was consolidated.

This sequencing is itself significant: it reveals a deliberate strategy, not an improvised opportunity. The first banks are proxy entities resistant to sanctions; they secure the ground while the major banks wait for the risk to decrease. It is a planned financial conquest, running parallel to the military conquest. And the **Russian Central Bank**, by regulating these entities, sits at the center of the financial chain of command.

### Coercion as state policy

The coercive mechanism documented is particularly brutal in its simplicity. **Russia** cuts Ukrainians' access to their own financial services (by neutralizing mobile towers, blocking Ukrainian ATMs), then offers as the only alternative a Russian banking system accessible only with a Russian passport. It is a double bind: no income or services without a Russian passport, but accepting the Russian passport tacitly validates the annexation.

For the elderly, who depend on their pensions to survive, the pressure is maximal. For the sick, who need medical care, it is a matter of life and death. **LexCo** explicitly describes medical care conditioned on a Russian passport as a crime against humanity — a form of persecution based on nationality, prohibited under the **Rome Statute**.

*An elderly woman from Kherson who cannot access her pension because she refuses a Russian passport. A sick person who cannot call an ambulance because he lacks a Russian social security number. These are LexCo's crimes. They are not legal abstractions — they are real lives. And someone in Moscow signed the regulations that created this system. That someone must answer for it.*

## The Russian central bank before the EU court

### The Luxembourg complaint: a delay strategy

While the **ICC** examines the complaint against its leaders, the **Russian Central Bank** itself has launched legal proceedings. In **February 2026**, it filed a complaint before the **EU General Court** in **Luxembourg** to obtain the annulment of the European regulation freezing its roughly **€210 billion** in assets. It alleges violations of property rights, sovereign immunity, and the principle of access to justice.

This approach is transparent in its strategy: to buy time. A proceeding before the **EU General Court** can take years before reaching a substantive decision. In the meantime, the assets remain blocked but their potential use to finance Ukrainian reconstruction or armament is legally contested. **Moscow** hopes that the tribunal's final decision, even if unfavorable, will be rendered in a different political context than today's.

### Russian arguments and their probability of success

European legal experts are broadly skeptical about the chances of success of the Russian complaint. The asset freeze was decided by the **EU Council** within the framework of its foreign and security policy powers — an area where judicial review of Council acts is limited. Furthermore, the **Court of Justice of the EU** has generally accorded wide discretion to the EU's political institutions on foreign policy decisions.

The argument about sovereign immunity is particularly fragile: in recent international jurisprudence, the sovereign immunity of a state that has committed unlawful armed aggression is not absolute. The **ICJ** (International Court of Justice) has established limits to this immunity in cases involving serious violations of international law. **Russia** invoking sovereign immunity for its assets, while having violated Ukrainian sovereignty through armed invasion, lacks singular argumentative consistency.

*The Russian Central Bank pleading sovereign immunity before an EU tribunal. There is absolutely perfect irony in that. Russia, which violated Ukrainian sovereignty for years, now invokes its own sovereign immunity to protect its assets. The audacity is admirable, in a way. But the Luxembourg judges will probably not be as impressed as I am.*

## Trump's reaction and the ICC's authority crisis

### Washington vs. The Hague: an open confrontation

American sanctions against **ICC** judges constitute a frontal attack on the authority of an international institution. The **Trump** administration imposed these restrictions in retaliation for the Court's investigations into allegations of war crimes involving American and Israeli nationals in **Afghanistan** and at **Gaza**. By reducing judges to an inability to pay their bills or travel freely, **Washington** hopes to intimidate them and slow these proceedings.

The resistance of the three judges — **Prost**, **Balungi Bossa**, and **Alini-Gou** — is significant. By bringing the case before an American federal court, they transform the geopolitical confrontation into an internal American legal dispute. They force American courts to rule on the legality of the sanctions under **IEEPA** — and potentially invalidate measures taken by the president. This is a bold strategy in a judicial environment under pressure.

### The impact on the ICC's credibility

These simultaneous attacks — from **Russia** through its non-cooperation and legal attempts to recover its assets, from the **Trump** administration through its sanctions against judges — place the **ICC** in a difficult defensive position. The institution needs the cooperation of member states to execute its arrest warrants and fund its operations. If the two largest military powers in the world coordinate (even indirectly) their hostility to the institution, its operational capacity is threatened.

And yet, the **ICC** continues. It has issued warrants against **Putin**. It is examining **LexCo**'s complaint. Its judges resist American pressure. This institutional resilience is, in itself, an important message: international law does not die because powers decide to ignore it. It retreats, it adapts, but it persists.

*I am fascinated by the ICC's tenacity under these circumstances. Neither Putin nor Trump wants it. And yet it holds. This is not institutional naivety — it is the demonstration that some institutions outlast their detractors. Nuremberg survived the Nazis. The ICC will survive its two current enemies.*

## LexCo's strategy: beyond individuals

### Unlocking frozen assets for the victims

**LexCo**'s long-term strategy goes beyond the individual conviction of **Nabiullina** or **Siluanov**. The ultimate goal is to create the legal conditions for the profits of crimes — notably Russian assets frozen in Western institutions — to be confiscated and returned to the victims. The legal theory is as follows: if Russian banks and the Russian central bank committed crimes, the proceeds of those crimes can be seized under the regime of criminally obtained property.

This mechanism, known as civil asset forfeiture, is well established in the domestic law of many countries — notably the **United States** and the **United Kingdom**. Transposed to international law, it would offer a basis for seizing not only the profits of frozen Russian assets but potentially the principal itself, for the benefit of Ukrainian victims. This is the link between **LexCo**'s complaint before the **ICC** and the broader debate about frozen Russian assets.

### A precedent for future conflicts

If the **ICC** accepts **LexCo**'s theory — even partially, even without a final conviction — the signal sent to central bankers and finance ministers around the world is clear: your role in an armed aggression exposes you personally to international criminal prosecution. This deterrent signal may be the initiative's most important impact, beyond any specific judicial outcome.

In **China**, where military planners are carefully studying Ukrainian precedents to calibrate possible future actions regarding **Taiwan**, this signal will be integrated into risk calculations. It adds a layer of personal risk for senior economic officials of a regime contemplating aggression: not only generals, but also bankers and finance ministers could end up in the **ICC**'s crosshairs.

*LexCo is building something larger than a criminal case. They are building a principle. A principle that says finance is not a consequence-free space in war crimes. That signing a banking license in illegally occupied territory commits you personally. I do not know whether this principle will prevail in the years ahead. But someone has to start establishing it.*

## Ukraine as victim and actor in this judicial process

### Kyiv and the multi-front legal strategy

**Kyiv** is simultaneously fighting several international legal battles: before the **ICJ** (International Court of Justice) on the Convention against systematic atrocities; before the **ICC** as a target of crimes whose perpetrators are being prosecuted; before the **ECHR** (European Court of Human Rights) on thousands of individual complaints; and now, indirectly, through **LexCo**'s complaint against the Russian bankers. This multiplicity is deliberate: **Ukraine** seeks to seal off every corridor of international accountability.

This multi-front legal strategy is a form of asymmetry: **Ukraine** cannot match **Russia** in military firepower, but it can pursue it in the institutions that **Moscow** helped build and now hopes to escape. Each complaint, each procedure, each arrest warrant reduces Russian diplomatic maneuver room and complicates the reconstruction of an international image for **Moscow** after the war.

### The hope of reparation for civilians in occupied territories

For Ukrainian civilians in occupied territories — those whose pensions were blocked, whose property was seized, whose access to medical care was conditioned on abandoning their national identity — **LexCo**'s complaint represents a promise: that their suffering will be recognized, documented, and perhaps compensated. If the effort leads to arrest warrants or confiscation of assets for the benefit of victims, the concrete impact on thousands of lives could be considerable.

The road is long and uncertain. **ICC** proceedings extend over decades. Frozen assets are subject to multiple disputes. Political resistance is immense. But the mere fact of having filed this complaint, of having documented and formalized the financial crimes of the occupation, is already a form of victory: the facts are established, the names are named, the legal mechanism is in motion.

*For that 41-year-old woman whose pension was being held hostage, for that sick person who had to prove Russian nationality before calling an ambulance — is LexCo's complaint much consolation? Probably not. International justice is slow and abstract. But it leaves a trace in the archives of law. And those traces eventually carry weight.*

## Comparative analysis: financial war vs. military war

### Two fronts of the same war

**LexCo**'s complaint reveals something essential about the nature of the Russian war in **Ukraine**: it is not limited to battlefields. It is also a financial war, waged by suited technocrats, with pens and banking licenses rather than shells. The imposition of the ruble, the seizure of Ukrainian banks, the financial control of occupied populations are instruments of the same policy as missile strikes: breaking Ukrainian resistance, forcing integration into the Russian empire.

Recognizing this financial dimension of the war also means recognizing that the response must be as financial as it is military. Sanctions, the asset freeze, **LexCo**'s complaint, the American **SABER Act** — all of these instruments aim to dismantle the financial support of Russian aggression and turn its own resources against it. This is total war, in the fullest sense of the term.

### The limits of the legal response

It would be naive to pretend the **ICC** can stop the war. It cannot. The arrest warrants against **Putin** did not prevent the bombardment of **Kyiv**. **LexCo**'s complaint will not prevent the next strikes on Ukrainian thermal power plants. International law is a delayed-effect tool, a long-term accountability mechanism, not an immediate shield.

But this time gap does not make it useless. It fits within a long-term strategy: making Russian aggression costly not only militarily and economically, but also legally and personally for its leaders. Each complaint filed, each warrant issued, each asset frozen reduces **Putin**'s and his entourage's comfort horizon. International law does not win wars. It complicates aggressors' victories.

*I want to be honest about the limits of what I am analyzing. The ICC will not save Ukrainian lives today. The law deploys over decades while the war unfolds by the hour. But the law builds the aftermath. The post-war, the post-Putin, the after all of this. And that aftermath will be better if someone took the trouble to build the files now.*

## The tension between current impunity and future accountability

### The temporal gap in international justice

One of the most frustrating paradoxes of international justice is its disconnect from the urgency of ongoing conflicts. **Nabiullina** continues to run the **Russian Central Bank**. **Siluanov** continues to sign the war budgets. The leaders of banks in occupied territories continue to operate. **LexCo**'s complaint is under examination. **ICC** proceedings take years. In the meantime, the crimes continue.

This gap is not a failure of the law — it is a feature of any serious judicial system. Crimes must be investigated, documented, and proven before being judged. Haste in convictions would produce different injustices. But it is important not to confuse judicial slowness with impunity: the files are building, the evidence is accumulating, the testimonies are being recorded. When the time comes — and it will come — it will be hard to claim ignorance.

### The signals of declining impunity

Despite the obstacles, the signals of declining impunity are real. The arrest warrant against **Putin** has changed his travel abroad. Dozens of Russian officials have been indicted by national courts in **Ukraine**, **Germany**, **Sweden**, and elsewhere. Russian frozen assets are not being returned to **Moscow**. **LexCo**'s complaint adds a new layer to this strategy of legal encirclement.

This accumulation of legal pressures has a real psychological effect on the Russian elite. Travel abroad is compromised. Assets hidden in Western democracies are exposed. The possibility of taking refuge in a third country after the war — a scenario considered by some Kremlin insiders according to independent sources — is becoming increasingly illusory. International law, even imperfect, is shrinking the options for escape.

*The Russian elite is beginning to realize that the world is shrinking. Putin can no longer go to Johannesburg, Pretoria, Brasília. Russian financiers can no longer hold meetings in Zurich or Geneva. Every arrest warrant, every indictment narrows their room for maneuver. It is slow. It is insufficient. But it is real.*

## Sanctions as an indispensable complement to criminal prosecution

### The double vice: ICC and sanctions regimes

**LexCo**'s complaint before the **ICC** does not operate in isolation. It fits within a broader ecosystem of pressure that includes the sanctions regimes of the **European Union**, the **United States**, the **United Kingdom**, and **Canada**. These two mechanisms — sanctions and criminal prosecution — reinforce each other. Sanctions freeze assets and restrict the movement of targets; criminal proceedings create a permanent legal record that does not disappear with a peace agreement or a change of government.

**Nabiullina** has already been sanctioned by the **EU**, the **United States**, and **Canada** since **2022**. These sanctions prevent her from accessing Western financial systems and traveling to the countries concerned. **LexCo**'s complaint adds a criminal dimension to this existing pressure: if the **ICC** issues an arrest warrant, the temporary character of sanctions (which can be lifted in a diplomatic agreement) is superseded by a permanent legal obligation for member states of the **Rome Statute** to arrest the suspect if she enters their territory.

### The complementarity between international pressure instruments

Lawyers working on Russian accountability have learned a crucial lesson from Balkan and African precedents: no single instrument is sufficient. Sanctions without criminal prosecution can be circumvented via intermediaries and tax havens. Criminal prosecution without sanctions leaves targets free in their financial movements. The combination of both creates a genuine gilded prison for senior **Moscow** regime officials — individuals who can remain in **Russia** but whose access to the outside world is structurally blocked.

This combined pressure strategy has another advantage: it outlasts political changes in Western countries. Sanctions can be eased by a **Trump** administration or a more cautious European coalition; **ICC** arrest warrants, once issued, are much harder to annul. **LexCo** aims to create lasting constraints, not cyclical pressures. It is a long-term strategic vision that goes beyond the current war.

*Sanctions are a political tool — they can be lifted if the political wind shifts. ICC arrest warrants are permanent. That is the difference between a conditional punishment and a liability inscribed in international law. LexCo wants Nabiullina to never be able to return to her Davos dinners, even after the war, even if the sanctions fall. That is an ambition that deserves our attention.*

## The impact on the doctrine of international financial accountability

### A potential jurisprudential turning point

If the **ICC** agrees to prosecute central bankers for their role in financing military aggression, it will be a major turning point in the doctrine of international criminal law. Until now, international criminal accountability has concentrated on military commanders, heads of state, and those directly politically responsible for atrocities. Extending this spectrum to financial technocrats — those who, through their expertise, make the war economy possible — would fundamentally change the perimeter of international accountability.

Precedents exist but are rare: beyond **Walther Funk**, the **Nuremberg** tribunal also tried industrialists such as **Friedrich Flick** and the **IG Farben** collective for their role in the Nazi war economy. **LexCo**'s theory fits within that lineage but adapts it to the **21st century** context: where the industrialists of **1945** directly exploited forced labor, the bankers of **2022–2026** administer the financial systems that make the occupation possible. The connection is more indirect but no less real.

### Institutional resistance and the future of the complaint

The **ICC** faces considerable institutional challenges. Its limited budget, its strained relations with some member states, and the already immense workload of its preliminary chambers are all factors complicating the acceptance of ambitious new legal theories. Prosecutor **Karim Khan**, recently reinstated despite **Washington**'s pressure, will have to weigh **LexCo**'s legal ambition against the institution's operational constraints.

Human rights organizations such as **Amnesty International** and **Human Rights Watch** have welcomed **LexCo**'s initiative while highlighting the procedural challenges. International civil society support is essential for maintaining political pressure on the **ICC** and on member states that might be tempted to moderate their backing under Russian diplomatic pressure. **LexCo**'s complaint is not only a legal act: it is a political act that needs a supporting ecosystem to progress.

*The ICC is an imperfect institution in an imperfect world. It has been ignored by great powers, circumvented, criticized — and yet it holds. It is the only permanent international criminal jurisdiction we have. Supporting LexCo means supporting the idea that even the most powerful must answer for their actions. That idea is worth fighting for.*

## Perspectives for the victims: between hope and legal realism

### The length of the judicial road

Let us be honest: the road from **LexCo**'s complaint to an effective conviction is extraordinarily long. **ICC** proceedings often extend over a decade or more. The **Bosco Ntaganda** case, begun in **2012**, ended in a conviction in **2019**. The case against **Jean-Pierre Bemba** lasted more than ten years. **LexCo**'s lawyers know that their clients — Ukrainian victims — will probably not see reparations in the immediate years ahead. International justice operates on the scale of generations, not electoral mandates.

This temporal reality creates a difficult tension. Current victims have immediate needs — pensions to receive, properties to recover, care to obtain. **LexCo**'s complaint operates on a timescale incompatible with these urgencies. That is why the international legal strategy must be accompanied by mechanisms of direct aid to victims — humanitarian aid funds, bilateral compensations, temporary indemnity mechanisms put in place by **Ukraine** and its allies.

### The symbolic and political importance beyond the verdicts

Even if **LexCo**'s complaint never leads to a formal verdict — which remains possible — its symbolic and political impact is already real. It has documented the mechanisms of financial occupation in legally precise terms. It has named the responsible parties. It has created a record accessible to researchers, journalists, and future prosecutors. This documentary capital will have lasting value, independent of any immediate judicial outcome. In the history of armed conflicts, the documentation of crimes is often the indispensable prerequisite for any future justice.

The most encouraging precedent may be that of the **former Yugoslavia**: victims of war crimes from the **1990s** waited decades, but the **ICTY** (International Criminal Tribunal for the former Yugoslavia) eventually tried and convicted dozens of military and political officials. **Slobodan Milošević** died before the end of his trial, but **Radovan Karadžić** is serving a life sentence in **The Hague**. For **Ukraine**, patience is not capitulation: it is a strategy.

*International justice is never as fast as the suffering it seeks to repair. This temporal asymmetry is one of the most profound cruelties of international law. But the alternative — abandoning justice because it is slow — is not an option. Ukrainian victims deserve both: aid now and justice later.*

## Conclusion: The law as a weapon of resistance

### LexCo and the refounding of international accountability

**LexCollective**'s complaint before the **ICC**, however uncertain its outcome, represents a major legal innovation in the treatment of war crimes. It poses a fundamental question that international law will eventually have to answer: how far does the accountability of those who provide the economic and financial infrastructure of an illegal occupation extend? If bankers, asset managers, and central bank technocrats can be held criminally accountable for their role in coercing occupied populations, the landscape of international accountability is fundamentally enlarged.

**Moscow**'s response — suing the **EU** for its own frozen assets, ignoring **ICC** warrants, sanctioning its judges via proxies — reveals that **Russia** understands the stakes. It is not fighting only a military war in **Ukraine**. It is fighting a war to define the rules of international accountability. And in that war, Western democracies, for all their imperfections, have a structural advantage: they believe in rules that bind them as much as their adversaries.

### A slow but necessary victory

Justice will not come tomorrow for Ukrainian victims. **ICC** proceedings extend over years, sometimes decades. But the documentation is underway. The names are named. The accountabilities are established. And the frozen Russian assets — which the **United States** now wants to use to fund Ukrainian weapons via the **SABER Act**, which the **EU** uses to fund its **€90 billion** loan to **Kyiv** — are the first concrete forms of this deferred justice. When **Nabiullina** signs the occupation bank licenses, she does not yet know that her signature may become her conviction.

*International law is an asymmetric weapon. It does not offset tanks, missiles, or bombs in the short term. But it builds lasting constraints, precedents, accountabilities that transcend wars and regimes. Ukraine is fighting with every available weapon. LexCo's complaint is one of them — less spectacular than an FPV drone, but perhaps more lasting in its effects.*

**By Maxime Marquette, columnist**

## Columnist's transparency note

### Editorial stance

I am not a journalist but a **columnist and analyst**. My expertise lies in observing and analysing the geopolitical, economic and strategic dynamics that shape our world. My work is to take political strategies apart, to understand global economic movements, to put the decisions of international actors in context and to offer analytical perspectives on the changes that are redefining our societies.

I do not claim the cold objectivity of traditional journalism, which stops at reporting facts. **I claim analytical clarity**, rigorous interpretation and a deep understanding of the complex issues that concern us all. My role is to give meaning to the facts, to place them in their historical and strategic context, and to offer a critical reading of events.

### Method and sources

This text keeps the basic distinction between **verified facts and interpretive analysis**. The rule never changes: a factual claim is published only when a verifiable source supports it, and the sources this article actually used are listed under **Sources**, never here.

**Primary source families** used by the publication, when the story has them: official statements from governments and international institutions, public statements by political leaders, reports from intergovernmental organisations, dispatches from recognised international news agencies.

**Secondary source families**: specialised publications, internationally recognised news media, analyses from established research institutions, reports from industry organisations.

When an article cites statistical, economic or geopolitical data, it comes from the institutions that produce it (intergovernmental organisations, central banks, national statistics offices), and the exact institution is named under **Sources**.

### Nature of the analysis

The analyses, interpretations and perspectives in the analytical sections of this article are a **critical, contextual synthesis** based on the information available, the trends observed and the expert comments cited in the sources consulted.

My role is to interpret these facts, to set them in the context of today's geopolitical and economic dynamics, and to give them a coherent meaning within the larger story of the changes shaping our time. These analyses reflect expertise built through continuous observation of international affairs and an understanding of the strategic mechanisms that drive global actors.

This article describes a documented state of affairs on its publication date, not a prediction: later developments may shift its outlook. No update is promised in advance; when an article is corrected or completed, the change is dated in the text.

## Sources

### Primary sources

- ['Stop treating Russia's bankers as faceless technocrats': inside the war crimes case against Russia's central bank — Euromaidan Press — May 18, 2026](https://euromaidanpress.com/2026/05/18/russia-financial-war-crimes-lex-collective-icc/)

- [ICC judges sue Trump over sanctions, call measures unlawful — Al Jazeera — June 25, 2026](https://www.aljazeera.com/news/2026/6/25/icc-judges-sue-trump-over-sanctions-call-measures-unlawful)

- [B4Ukraine — Putin's Top Central Banker Accused of Complicity in War Crimes in ICC filing](https://b4ukraine.org/what-we-do/icc-war-crimes-filing-nabiullina-siluanov)

### Secondary sources

- [International Criminal Court — Situation in Ukraine — Putin arrest warrant 2023](https://www.icc-cpi.int/situations/ukraine)

- [LIGA.net — International Criminal Court asked to recognize Nabiullina as an accomplice in Putin's crimes — 2025](https://finance.liga.net/en/ekonomika/novosti/international-criminal-court-asked-to-recognize-nabiullina-as-an-accomplice-in-putins-crimes)

- [Charter97 — International Criminal Court Asked To Issue Arrest Warrants For Nabiullina — July 2025](https://charter97.org/en/news/2025/7/16/648454/)

- [Ground News — Russia's Central Bank Sues EU in Luxembourg Over Frozen Assets — June 2026](https://ground.news/article/russias-central-bank-sues-eu-in-luxembourg-over-frozen-assets_d24d80)

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Source: Maxime Marquette, MadMax. When citing, name the author and link https://mad-max.co/en/article/analyse-la-cpi-la-banque-centrale-russe-et-la-requalification-des-crimes-financi