In response to Russia’s hostile invasion of Ukraine last week, Canada, along with the United States and many of the world’s largest trading nations, has issued new sanctions and other measures restricting dealings with Russia.
On February 24, Canada amended the Special Economic Measures (Russia) Regulations twice. First in response to Russian recognition of the independence and sovereignty of the so-called “people’s republics” in the Ukrainian regions of Donetsk and Luhansk, by adding 351 members of the State Duma to Schedule 1, three entities to Schedule 3.1, two entities to Schedule 1, new prohibitions on Russian sovereign debt, and new criteria for listing targets. Second, in response to Russia’s military attack against Ukraine’s territory in the DNR and LNR regions, by adding 31 new individuals and 19 new entities to Schedule 1 of the Regulations.
Canada’s new regulations in this regard provide for the following:
Asset Freeze & Dealings Prohibition
Persons subject to the Canada regulation are broadly prohibited from dealing in the property of such designated individuals or entities, facilitating such dealings, or otherwise conferring certain economic benefits to such individuals and entities. In addition to various Russian individuals, the asset freeze applies to a series of significant Russian companies and financial institutions, going beyond current blocking measures employed by the United States.
With some exception, dealing in new debt of varying lengths of maturity and in securities of designated individuals or entities are prohibited. The export, sale, supply, or shipping of specified goods to Russia or Russian persons for use in offshore, shale oil, or Arctic oil exploration and production are similarly prohibited. Included in the prohibition is a ban on the provision of financial, technical, or other services related to the specified goods.
Controlled Goods & Technology
Also on Feb. 24, Global Affairs Canada issued notification that effective immediately, Canada will stop the issuance of new permits for the export and brokering of controlled goods and technology to Russia. As a result, exporters with valid permits for the export or brokering of items to Russia prior to Feb. 24 will have their permits immediately cancelled.
Similar to the United States, exceptions to Canada’s asset freeze and dealings prohibition include certain payments made pursuant to contracts entered into before the new regulations went into force, as well as transactions by international organizations.
Additionally, Global Affairs Canada advises that permits and applications related to specific end-uses such as medical supply and humanitarian needs may be considered for exception, on a case-by-case basis.
The latest additions to Canada’s listings can be found here and here.
For further information, please contact the Export Controls Division at Global Affairs Canada by phone at 613-996-2387 or via e-mail.