On June 13, 2024, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments list an additional 12 individuals and 16 entities under Schedule 1 of the Regulations and place export prohibitions on an additional 5 categories of goods under Schedule 7 of the Regulations. The amendments took effect on June 12, 2024.

The Schedule 1 sanctions target individuals and entities implicated in disinformation and propaganda operations regarding Russia’s illegal war in Ukraine. They also include entities in Russia’s military-industrial complex that supply key electrical components in support of Russia’s war efforts, and entities involved in sanctions circumvention that facilitate Russia’s access to sanctioned goods or revenue from oil sold above the G7 price cap.

The Regulations impose a dealings prohibition against the individuals and entities listed, 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.

The amendments to Schedule 7 of the Regulations prohibits the export of goods classified under sub-headings 84.57, 84.58, 84.59, and 84.66 of Canada’s customs tariff, which includes machining centres for working metal and computer numerically controlled machining tools (commonly referred to as “CNC machines”). Canada prohibited the export of these goods due to their potential use in the production and manufacture of weapons.

Canada has coordinated these sanctions with its international partners at the G7 Summit in Italy, which took place June 13 to 15, 2024.

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 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 12, 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.