On April 15, 2024, Canada announced further amendments to the Special Economic Measures (Belarus) Regulations (the “Regulations”). These amendments list an additional 21 individuals under Schedule 1 of the Regulations in response to ongoing human rights violations in Belarus. The amendments took effect on April 12, 2024.

The announcement follows a visit by the exiled Belarusian opposition leader, Sviatlana Tsikhanouskaya, to Ottawa. The individuals targeted are current and former senior government officials involved in human rights abuses committed by the Alexander Lukashenko-led government and the prosecution of Belarusians protesting the results of the 2020 Belarus presidential election. More specifically, the newly listed individuals are members of Belarusian security forces, public prosecutors, members of the judiciary system and administrators of penal and “education” colonies that are connected with the arrest, detention, intimidation, imprisonment, and excessive use of force against protesters.

Canada has coordinated its sanctions with the European Union, which has already sanctioned these individuals, and the US which has also recently announced several Belarus-related measures.

There are now 211 individuals and 71 entities listed in Schedule 1 of the Regulations. To read more about Canada’s previous round of Belarus sanctions, read our August 2023 blog post here.

The Regulations impose a dealings prohibition against the individuals 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 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 (Belarus) Regulations that came into effect on April 12, 2024 are available on Global Affairs Canada’s website here.


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.