On November 14, 2022, Prime Minister Trudeau announced additional amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments target twenty-three individuals, identified as “members of the Russian justice and security sectors, including police officers and investigators, prosecutors, judges, and prison officials”. The sanctions took effect as of November 10, 2022. There are now over 1,090 individuals listed under Schedule 1 of the Regulations.
The twenty-three individuals are listed in Part 1.1 of Schedule 1 of the Regulations.
Generally speaking, designation under Schedule 1 of the Regulations imposes an asset freeze and dealings prohibition against the designated person. Subject to limited exceptions, any person in Canada or any Canadian outside Canada cannot:
- deal in any property, wherever situated, that is owned, held or controlled 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 available any goods, wherever situated, to a designated person listed in Schedule 1 or to a person acting on their behalf; or
- provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.
Additionally, individuals listed in Part 1.1 of Schedule 1 of the Regulations are also inadmissible to Canada under the Immigration and Refugee Protection Act.
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 held 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 held by Schedule 1 entities.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on November 10, 2022 are available on Global Affairs Canada’s website at here.
