On March 14, 2019, Canada announced a new round of targeted sanctions against Russia for its continued involvement in Ukraine, adding 114 individuals and 15 entities to its Russia and Ukraine sanctions regulations.

Canada has cited Russia’s involvement and escalation in the Kerch Strait – an important transit point for ships en route to major Ukrainian export terminals – as a reason for the new sanctions.

The new individuals and entities are added to “Schedule 1” of the Special Economic Measures (Russia) Regulations  and the
“Schedule” to the Special Economic Measures (Ukraine) Regulations, which makes them “designated persons” subject to the strictest prohibitions under Canadian sanctions law. The sanctions impose asset freezes and dealings prohibitions on designated persons, whereby Canadian individuals and corporations are broadly prohibited from engaging in substantially all trading activities or transactions related to a designated person or property held by a designated person. More specifically, it is prohibited for any person in Canada and any Canadian outside Canada to:

(a)   deal in any property, wherever situated, held by or on behalf of a designated person;

(b)   enter into or facilitate, directly or indirectly, any transaction related to a dealing referred to in paragraph (a);

(c)   provide any financial or other related service in respect of a dealing referred to in paragraph (a);

(d)   make any goods, wherever situated, available to a designated person; or

(e)   provide any financial or related service to or for the benefit of a designated person.

Canadian persons, in or outside of Canada, that conduct business with Russia should review this expanded list and ensure they are not engaging in any prohibited activities under Canada’s sanctions regulations. The lists of newly sanctioned individuals and entities are available in the Regulations Amending the Special Economic Measures (Russia) Regulations and Regulations Amending the Special Economic Measures (Ukraine) Regulations.



Quentin focuses his practice on Canadian and international trade law matters, including Canadian customs, trade remedies, export controls, Canadian economic sanctions, free trade agreements – such as NAFTA, CPTPP and CETA – product regulations, and other issues impacting the cross-border movement of goods. Quentin helps international and domestic clients design optimal strategies for cross-border trade through duties relief, tariff classification, value for duty assessments, advance rulings, rules of origin and tariff preferences. Quentin also represents clients in trade compliance verifications or audits by the Canadian Customs authorities (the Canada Border Services Agency), as well as trade remedy inquiries and customs appeal proceedings before the Canadian International Trade Tribunal (CITT). Quentin currently serves as Vice-Chair of the International Law Section of the Ontario Bar Association. He is also a member of the Canadian Association of Importers and Exporters and the Canadian Society of Customs Brokers (CSCB), among others. Quentin is fluent in French.