On 23 March, Canada amended its sanctions measures imposed on Russia by designating an additional 160 individuals under Schedule 1. The new individual designations consist of Russian officials who are members of the Russian Federation Council. With these designations, all members of the Russian Federation Council are now designated by Canada. This amendment also modifies the prohibitions applicable to designated persons by including in the prohibition dealing in any property owned or controlled by a designated person or to make available any goods to a person acting on behalf of a designated person.
As a result of these amendments, generally speaking, 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, that is owned, held or controlled 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 available any goods, wherever situated, to a designated person listed in Schedule 1 or to a person acting on their behalf; or
- Provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.
Due to ongoing developments in the region, Canada may announce and implement further measures in the coming days. We will publish additional articles as measures are announced in an official capacity.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on 23 March are available on Global Affairs’ website at here.
