On June 27, 2022, in furtherance of discussions at the G7 Summit, Canada amended its sanctions measures with respect to Russia, Belarus and Ukraine;
Russia
- Adding six Russian senior defence officials and 46 Russian defence-sector entities as designated persons under Schedule 1;
- Prohibiting any person in Canada and any Canadian outside of Canada from exporting, selling, supplying or shipping any good, wherever situated, or providing any technology, to Russia or to any person in Russia if the good or technology is referred to in the new Schedule 5.1. Canada has indicated that the goods and technologies listed in Schedule 5.1 could be used in the production and manufacturing of weapons by Russia. Schedule 5.1 includes items such as quantum computers and related advanced manufacturing equipment.
Ukraine
- Adding 15 former senior officials and their family members, as well as so-called leaders in areas of Ukraine illegally occupied by Russian forces as designated persons under Schedule 1.
Belarus
- Designating an additional 13 Belarusian senior officials of the Ministry of Defence under Part 1.1 of Schedule 1, and two Belarussian military entities under Part 2 of Schedule 1;
- Imposing a ban on imports from, and exports to, Belarus of certain luxury goods that are set out in a new Schedule 4. This import and export ban comes into effect 60 days from June 27, 2022 (the day on which these amendments came into effect);
- Prohibiting persons in Canada and Canadians outside Canada from exporting, selling, supplying or shipping any goods or technology, wherever situated, to Belarus or any person in Belarus that is described on the Restricted Goods and Technologies List or in the new Schedule 3;
- Prohibiting persons in Canada and Canadians outside Canada from exporting, selling, supplying or shipping any goods, wherever situated, to Belarus or any person in Belarus that is described in newly-added Schedule 5, which are items that could be used in the manufacturing of weapons to Belarus.
Impact of Schedule 1 Designation
The Schedule 1 designation under the Regulations for Russia, Ukraine and Belarus 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 or entity whose name is listed in Schedule 1;
- enter into or facilitate, directly or indirectly, any transactions 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 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.
More to Come
Due to ongoing developments in the region, the Government of Canada has signalled its intent to introduce further sanctions in the near future. It has listed potential sanctions against “state-sponsored disinformation and propaganda agents and entities,” and in coordination with the United States, United Kingdom, and Japan, an import ban on certain gold goods from Russia. 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 June 27th are available on Global Affairs’ website at here.
An unofficial copy of the legislative amendments to the Special Economic Measures (Ukraine) Regulations that came into effect on June 27th are available on Global Affairs’ website at here.
An unofficial copy of the legislative amendments to the Special Economic Measures (Belarus) Regulations that came into effect on June 27th are available on Global Affairs’ website at here.
A copy of the Restricted Goods and Technologies List is available here.
