On May 18, Canada amended its sanctions measures imposed on Russia by designating an additional fourteen 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, on May 17, the Government of Canada announced it will take legislative action to ban persons subject to sanctions in Canada and any accompanying family members from entering the country.
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.
Canada also introduced a prohibition on the export and import of luxury goods listed under Parts 1 and 2, respectively, to Schedule 6 which will take effect 60 days after entry into force. These measures prohibit any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any goods on Part 1, Schedule 6, wherever situated, or importing, purchasing or acquiring any goods on Part 2, Schedule 6 wherever situated, to or from Russia or any person in Russia.
Finally, Canada announced a prohibition on the export of a broad range of goods that the Government of Canada has determined could be used to support the manufacture of weapons, which will take effect 60 days after entry into force. These measures prohibit any person in Canada and any Canadian outside of Canada from exporting, selling, supplying, or shipping any good listed in column 1 of Schedule 7, wherever situated, to Russia or to any person in Russia. A list of exceptions is applicable in specific cases.
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 18th is available on Global Affairs’ website at here.