Effective July 14, 2021, the Government of Canada imposed new sanctions against 15 individuals pursuant to the Regulations Amending the Special Economic Measures (Nicaragua) Regulations.  The sanctions were imposed in response to alleged ongoing human rights violations being committed in Nicaragua.

Listed persons under the Special Economic Measures (Nicaragua) Regulations (the “Regulations”) are considered inadmissible to Canada under the Immigration and Refugee Protection Act.  In addition, the Regulations effectively impose an asset freeze on listed persons because, subject to prescribed exceptions, it is prohibited for any person in Canada and any Canadian outside of Canada to:

  • deal in any property, wherever situated, that is owned, held or controlled by a listed person or by a person acting on behalf of a listed person;
  • enter into or facilitate any transaction related to a dealing referred to in paragraph (a) above;
  • provide any financial or related services in respect of a dealing referred to in paragraph (a) above;
  • make available any goods, wherever situated, to a listed person or to a person acting on behalf of a listed person; and
  • provide any financial or related service to or for the benefit of a listed person.

The Regulations further prohibit any person in Canada and any Canadian outside of Canada from knowingly doing anything that causes, facilitates or assists in, or is intended to cause, facilitate or assist in any of the prohibited activities described above. For additional background information, please see the press release (here) from the Government of Canada regarding the imposition of these sanctions.

Author

Jacqueline Rotondi is an associate in Baker McKenzie's International Commercial Practice Group in Toronto.