On May 7, 2016, the Government of Canada announced that it will lift its comprehensive trade sanctions against Belarus. The change reflects Canada’s acknowledgement of the recent actions taken by the Government of Belarus, including the release of political prisoners and a presidential election marked by improved adherence to international norms. Lifting sanctions against Belarus will bring Canada into alignment with actions taken by the United States and European Union since October 2015.

Canada imposes sanctions against Belarus by listing Belarus on the Area Control List (“ACL”) made pursuant to the Export and Import Permits Act (“EIPA”). The EIPA prohibits the export or transfer of all goods and technology to a country listed on the ACL without an export permit. Currently only Belarus and North Korea are listed on the ACL.

Since it will take some time for the regulatory process to be completed to remove Belarus from the ACL, Global Affairs Canada has announced that it will issue export permits as a matter of course for any goods and technology not listed on the Export Control List (“ECL”) that are to be exported to Belarus. Goods and technology listed on the ECL generally include nuclear or military goods and technology, and certain “dual-use” goods and technology (reflecting Canada’s commitments under the Wassenaar Arrangement). Goods and technology listed on the ECL may not be exported to any country (with exceptions for certain goods and technologies exported or transferred to the United States) without an export permit.