On January 27, 2025, the Government of Canada announced further amendments to the Special Economic Measures (Belarus) Regulations (“the Regulations”). These amendments list an additional 10 individuals and 12 entities in Schedule I of the Regulations.
These sanctions were announced in coordination with the United Kingdom and include three Belarusian state organizations that are stated to have been involved in human rights violations and nine entities that are stated to be part of the Belarusian military-industrial complex providing production and supplying military equipment for Russia’s war in Ukraine. Certain targeted individuals are also senior officials of these entities. Other newly listed individuals include those who are directly connected with individuals already sanctioned for their involvement in human rights violations.
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:
(a) dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
(b) entering into or facilitating any transaction related to a dealing in a designated person’s property;
(c) providing any financial or related services in respect of a dealing in a designated person’s property;
(d) making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
(e) 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
(f) 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 made 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 (Belarus) Regulations that came into effect on January 24, 2025 are available on Global Affairs Canada’s website here.
