We reported in previous blog posts (here, here and here) that Canada has continued to expand its sanctions regime alongside the US and the EU. Since June 21, 2014, Canada has further expanded its sanctions against Russia and Ukraine. Summarized below are the amendments since that date.
Special Economic Measures (Ukraine) Regulations
On June 21, 2014, the Special Economic Measures (Ukraine) Regulations (“Ukraine Regulations“) were amended with the addition of 10 individuals and one entity to the designated persons list.
On July 11, 2014, the Ukraine Regulations were amended by the addition of 14 individuals as designated persons.
On July 24, 2014, further amendments were made to the Ukraine Regulations with the addition of eight individuals and two entities as designated persons.
The most recent amendments to the Ukraine Regulations were made on August 6, 2014. Five individuals and 16 entities were added as designated persons.
The various regulations amending the Ukraine Regulations can be found on the Department of Foreign Affairs, Trade and Development Canada (“DFATD“) website here.
Special Economic Measures (Russia) Regulations
Since June 21, 2014, there have also been a number of amendments to the Special Economic Measures (Russia) Regulations (“Russia Regulations“) adding both individuals and entities as designated persons and also expanding the sanctions applicable to certain designated persons.
On June 21, 2014, the Russia Regulations were amended with the addition of one individual as a designated person.
On July 24, 2014, more extensive amendments were made to the Russia Regulations. The existing schedule of designated persons was renamed Schedule 1 and two additional schedules of designated persons were added.
In addition to these new schedules, two new sanctions were introduced targeting the persons named on Schedules 2 and 3.
The first new sanction prohibits any person in Canada and any Canadian outside Canada from transacting in, providing, or otherwise dealing in a loan, bond or debenture, of longer than 90 days’ maturity in relation to a designated person listed in Schedule 2 or 3, the property of a designated person listed in Schedule 2 or 3, or the interests or rights in property of a designated person listed in Schedule 2 or 3. This prohibition, however, does not apply in respect of a loan that was made, or a bond or debenture that was issued before the designated person was listed in Schedule 2 or 3.
The second added sanction prohibits any person in Canada and any Canadian outside Canada from transacting in, providing, or otherwise dealing in capital funding through the transaction of shares in exchange for an ownership interest in relation to a designated person listed in Schedule 2, the property of a designated person listed in Schedule 2, or the interests or rights in property of a designated person listed in Schedule 2. This prohibition does not apply to any capital funding that occurred before the designated person was listed in Schedule 2.
The amendments made on July 24, 2014 also added seven entities to Schedule 1, two entities to Schedule 2, and one entity to Schedule 3.
On August 6, 2014, the Russia Regulations were further amended with the addition of 14 individuals and three entities to Schedule 1, and three entities to Schedule 2.
The various regulations amending the Russia Regulations can be found on the DFATD website here.
