On April 28, 2014, the Department of Foreign Affairs, Trade and Development Canada (“DFATD”) amended the Special Economic Measures (Russia) Regulations to expand the list of designated persons to include 9 new individuals and 2 new entities. The two entities that have been added to the list of designated persons are “ExpoBank” and “RosEnergoBank”, neither of which has been sanctioned by the United States or the European Union.
These amendments are just the latest instalment of amendments to the Special Economic Measures (Ukraine) Regulations and Special Economic Measures (Russia) Regulations that have occurred in the past few weeks since these sanctions were originally introduced on March 17, 2014. DFATD indicates that these sanctions were introduced to address the political unrest caused by former Ukraine President Viktor Yanukovych and his associates, and the gravity of Russia’s violation of the sovereignty and territorial integrity of Ukraine. Given the current political climate and events in Ukraine, we expect that the list of names and entities named under the sanctions will likely continue to expand.
Furthermore, as demonstrated by the latest round of amendments to the Special Economic Measures (Russia) Regulations, it appears to be the case that Canada, the European Union and the United States do not always agree on which individuals or entities should be sanctioned. Companies should therefore carefully assess their activities with respect to Russia and Ukraine to ensure compliance with all applicable sanctions.
An official copy of the Special Economic Measures (Russia) Regulations that is current to April 16, 2014 can be found here.
An unofficial copy of the The Regulations Amending the Special Economic Measures (Russia) Regulations that were enacted on April 28, 2014 naming the nine additional individuals and two additional entities can be found on DFATD’s website.
An official and up-to-date copy of the Special Economic Measures (Ukraine) Regulations can be found here.
