On December 12, 2023, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”) sanctioning an additional 30 Russian nationals under Schedule 1 of the Regulations. The amendments came into effect on December 8, 2023.
The individuals added to Schedule 1 allegedly participated as candidates in Kremlin-organized elections held from September 8 to 10, 2023, in the occupied region of Kherson Oblast in southern Ukraine. The Government of Canada characterizes these elections as a “sham”, “illegal”, and as part of Russia’s strategy to legitimize the invasion of Ukraine by enabling the imposition of Russian law, media, education and currency on Ukrainians.
These sanctions follow a September 2023 joint statement issued by the G7 foreign ministers condemning the elections held by Russia on sovereign Ukrainian territory in Donetsk, Kherson, Luhansk, Zaporizhzhia and Crimea.
Schedule 1 of the Regulations imposes a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act. For more information on the dealings prohibition and Canada’s new deeming provision under the Special Economic Measures Act, read our previous blog post on Canada’s November 2023 Russia sanctions here.
Since February 2022, Canada has continually updated the Regulations, as well as the Special Economic Measures (Belarus) Regulations, the Special Economic Measures (Ukraine) Regulations, and the Special Economic Measures (Moldova) 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 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 (Russia) Regulations that came into effect on December 8, 2023 are available on Global Affairs Canada’s website here.