On March 10, Canada amended its sanctions measures imposed on Russia by designating an additional 5 individuals and 32 entities. The new individual designations consist of current and former Russian officials as well as associates of the Russian government. The new designated entities consist of Russian entities associated with the defence industry..
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, 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 on March 10 also implemented a ban on specific Russian petroleum products as announced by the Canadian government on February 28, 2022. The amendments prohibit any person in Canada and any Canadian outside Canada to import, purchase or acquire any good listed in Schedule 5, wherever situated, from Russia or from any person in Russia (note that exceptions may exist with respect to the import of these goods if contracts in respect of their procurement were concluded prior to March 10th).
The goods listed under Schedule 5 by the amendment consist of:
- petroleum oils and oils obtained from bituminous minerals, crude;
- petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70% or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils;
- petroleum gases and other gaseous hydrocarbons.
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.
An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on March 10th are available on Global Affairs’ website at here and here.
