Greece and Malta lag behind their European Union peers in freezing Russian assets sanctioned over Moscow’s war against Ukraine, according to an EU official and an internal document, as the bloc considers confiscating the funds to help Kyiv.

The 27 EU countries have so far reported freezing some 20.3 billion euros ($22 billion) of sanctioned Russian assets, with Italy, Ireland, France, Spain, Germany, Belgium, Luxembourg and Austria each notifying actions totalling more than a billion euros.

Almost every other EU country has frozen millions worth of assets, according to the document from the EU’s executive European Commission, which was seen by Reuters.

By comparison, Greece had only notified the bloc of freezing assets worth 212,000 euros, and Malta 147,000 euros.

“That is a bit surprising,” said the EU official, who spoke under condition of anonymity.

“Either they don’t have much, or they are not doing their job. Or they have done something but not communicated to us even though they had chances.”

Greece and Malta did not immediately respond to a request for comment.

More than 10 months since Russia’s attack on Ukraine, the EU currently has some 1,300 individuals and 120 entities blacklisted, as well as economic sanctions in place that include trade, transport, energy, banking, media and defence sectors.

But the bloc might have already exhausted the limit of hard-hitting economic sanctions the 27 member states are willing to agree and impose, despite regular calls from Russia hawks including Poland to do more.

The EU’s attention turns this year to how and whether to confiscate the frozen Russian assets, and spend it on rebuilding Ukraine, an exercise where an estimated 300 billion euros worth of Russian central bank assets in Europe could also be at stake.

There is little legal precedent and some member states voice major concerns about ensuing lawsuits, while others say turning the assets over to Ukraine’s benefit would be the right thing to do.

Linked to that, the EU is also working on making bypassing sanctions a criminal offence in all the member states, which is not the case currently.

The official said the bloc’s top brass should be able to announce progress on those matters when they travel to Kyiv for an EU-Ukraine summit on Feb. 3.