On May 16, 2024, the Minister of Foreign Affairs announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”) sanctioning additional Russian individuals and entities. The amendments list an additional 2 individuals and 6 entities under Schedule 1 of the Regulations and took effect on May 16, 2024.

Schedule 1 of the Regulations imposes a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act. The entities and individuals added to Schedule 1 of the Regulations are alleged to have facilitated the illegal transportation of weapons from North Korea to Russia that were used in Russia’s war in Ukraine.

Since February 2022, Canada has continually updated the Regulations, as well as the Special Economic Measures (Belarus) Regulations and the Special Economic Measures (Ukraine) Regulations. Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property owned or controlled by Schedule 1 entities and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property owned, held or controlled by Schedule 1 entities.

An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that entered into force on May 16, 2024 are available on Global Affairs Canada’s website here.

Author

Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.