On May 3, Canada amended its sanctions measures imposed on Russia by designating an additional twenty-one individuals under Schedule 1. The new individual designations consist of persons identified by the Government of Canada as oligarchs, close associates of the Russian regime, and members of their family.
As well, Canada repealed Schedule 6, a list of partner countries to which certain exceptions apply that are relevant to the measures related to the Restricted Goods and Technologies List. It has been replaced with Annex 1 to the Restricted Goods and Technologies List, which will now serve the same function.
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 alignment with its allies in the coming days. We will publish additional articles as measures are announced.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on May 3rd are available on Global Affairs’ website at here.