Further to our recent blogs here and here, Canada has announced even more measures to isolate Russia on the world stage.

Specifically, Canada joined other G7 nations to impose new Russian sanctions, announced in connection with the G7 Leaders’ Summit today in Hiroshima.

In short, over 70 new sanctions were announced, focussing on people viewed as “supporting Russia’s illegal military action and complicit in human rights violations”.  According to the Prime Minister’s Office, the sanctions target “17 individuals and 18 entities linked to Russian companies that provide military technology and know-how to Russia’s armed forces, family members of listed persons, and members of the Kremlin elite.”

Overview of Current Sanctions

There is currently a myriad of regulation aimed at Russia, with many of these sanctions implemented through the Special Economic Measures (Russia) Regulations, and more specifically the Special Economic Measures (Ukraine) Regulations and the Special Economic Measures (Russia) Regulations – the latter of which have been amended over 30 times since 2014.

In general terms the sanctions impose an asset freeze and dealings prohibition on designated persons listed in Schedule 1, which include both individuals and entities. For example, under these rules it is legally prohibited for any person in Canada and any Canadian outside Canada to:

• deal in any property, wherever situated, held by or on behalf of a designated person whose name is listed in Schedule 1;
• enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
• provide any financial or other related services in respect of such a dealing;
• make any goods, wherever situated, available to a designated person listed in Schedule 1; or
• provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.

The individuals listed in Part 1.1 of Schedule 1 to the Regulations are also inadmissible to Canada under the Immigration and Refugee Protection Act.

The individuals sanctioned are largely senior management at Russian companies that provide military services to Russia or other persons are linked to Russian companies that provide military technology and know-how to Russia’s armed forces, family members of listed persons, and members of the Kremlin elite.

Canada also listed 30 individuals and 8 entities involved in Russia’s ongoing human rights violations, including the transfer and custody of Ukrainian children in Russia.

What Should I be Doing?

Persons that find themselves dealing with Russia in 2023 ought to be extremely mindful of Canada’s sanctions regime and take steps necessary to determine whether their business dealing with Russia are legally permissible.

Do you require assistance in this area? If so, please click here.

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