On June 18, 2024, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments list an additional 13 individuals under Schedule 1 of the Regulations and took effect on June 13, 2024.
Theses sanctions are imposed in relation to the February 16, 2024 death of imprisoned Russian opposition leader Alexei Navalny and Russia’s continued systematic violations of human rights. The 13 additional sanctioned individuals are senior officials and high-ranking employees of Russia’s investigation agency, penitentiary service and police force.
The Regulations impose a dealings prohibition against the individuals effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
- dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
- entering into or facilitating any transaction related to a dealing in a designated person’s property;
- providing any financial or related services in respect of a dealing in a designated person’s property;
- making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
- transferring or providing any property other than goods to a listed person or to a person outside Canada who is not Canadian for the benefit of a designated person; or
- providing any financial or related services to or for the benefit of a designated person.
Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.
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 parties and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property of Schedule 1 parties.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on June 13, 2024 are available on Global Affairs Canada’s website here.
