On March 4, Canada amended its sanctions measures to designate an additional 10 individuals under Schedule 1. These new designations are individuals identified by the Canadian Government as executives of Rosneft and Gazprom. On March 6, Canada further amended Schedule 1 to designate 10 more individuals determined by the Canadian Government to be current or former senior government officials, their close associates or so-called “agents of disinformation.”

The designation under Schedule 1 imposes an asset freeze and dealings prohibition, subject to limited exceptions, which prohibits any person in Canada or any Canadian outside Canada to:

  • deal in any property, wherever situated, held by or on behalf of a designated person whose name is listed in Schedule 1;
  • enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
  • provide any financial or other related services in respect of such a dealing;
  • make any goods, wherever situated, available to a designated person listed in Schedule 1;
  • provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.

The amendments enacted on March 6th also imposed an additional sanctions measure prohibiting any person to dock in Canada or pass through Canada any ship that is registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a designated person, unless such docking or passage is necessary to safeguard human life or to ensure navigational safety.

Due to ongoing developments in the region, Canada may announce and implement further measures in alignment with its allies in the coming days. We will publish additional articles as measures are announced in an official capacity.

Unofficial copies of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on March 4th and 6th respectively, are available on Global Affairs’ website at here, here and here.