Tax & Trade Blog

As we have previously reported on here and here, Canada has continued to expand its economic sanctions on Russian nationals, following Russia’s invasion of Ukraine, targeting individuals and entities believed to be linked to the Russian regime.

Canada’s sanctions have been primarily imposed under the Special Economic Measures (Russia) Regulations (the “Russia Regulations”), the Special Economic Measure Act (“SEMA”), and through other similar regulations targeting persons in Belarus, Ukraine and most recently Moldova.  In total these sanctions include asset freezes and financial prohibitions, and even apply to certain listed persons set out in the Schedules within the regulations.  These lists change frequently, are hard to get off of, and have impacted more than 2,900 individuals and entities.

The Canadian government can and does impose sanctions against foreign States and non-state entities through a complex formula involving several different Acts and regulation sets.  Navigating through this myriad of rules can be daunting.

Overview of Canada’s Sanctions Regime

Global Affairs Canada is the overall regulator of Canadian sanctions, and has just released some long-awaited clarifications on the scope of Canada’s current sanctions, which comes in response to the Canadian Senate’s 2023 Standing Committee Report on Foreign Affairs and International Trade.