Canada’s Latest Sanctions Against Russia, Belarus, Ukranian Individuals

On June 27, 2022, Canada announced a new round of sanctions against Russia and Belarus and against Ukrainian individuals imposed under the Special Economic Measures Act by way of amendments to the Special Economic Measures (Russia) Regulations (“Russia Regulations”), the Special Economic Measures (Belarus) Regulations (“Belarus Regulations”), and the Special Economic Measures (Ukraine) Regulations (“Ukraine Regulations”).

Russia Regulations

The new Russian sanctions prohibit the trade with Russia of certain “Restricted technologies” which include advanced technologies and goods that could be used to improve Russia’s domestic defence manufacturing capability. These items include components, materials, software, and technology related to quantum computers and advanced manufacturing equipment. Canada also sanctioned six (6) Russian individuals because they were elites or close associates of the Russian-regime and forty-six (46) Russian financial, defence, and energy entities.

Belarus Regulations

The new Belarussian sanctions bans the importation of luxury goods from Belarus as well as the export from Belarus of luxury goods, advanced technologies, and goods which could be used in the manufacturing of weapons. Canada also sanctioned thirteen (13) close individuals which it asserts are associates of the President of Belarus, Alexander Lukashenko, and two (2) corporate entities because Canada states that they enabled Russia’s invasion of Ukraine.

Ukraine Regulations

Through the new sanctions implemented under the Ukraine Regulations, Canada is targeting fifteen (15) individuals that it states are Russian-backed proxies, including senior officials and their family members, sanctioned for their complicity in Russia’s invasion of Ukraine.

Our team will continue to monitor the sanctions measures related to Russia, Ukraine, and Belarus providing updates to keep clients informed about important developments affecting trade and services. The lawyers at Tereposky & DeRose have significant experience in the design and implementation of sanctions-related compliance programs, including policies, procedures, employee training, and internal control mechanisms. They also regularly assist both Canadian and international businesses, financial institutions, and individuals with internal investigations when “red flags” appear and provide advice on compliance in these areas. Where breaches have occurred, they have worked closely with their clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.

Vince DeRose
613.237.8862
vderose@tradeisds.com

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Peter Knowlton
613.237.4742
pknowlton@tradeisds.com

Congratulations | Félicitations

Congratulations to Stephanie Desjardins who was elected as a member of the Board of Directors of the Réseau Francophone de Droit International (RFDI), and selected as Treasurer of the Bureau!

The RFDI is an association that gathers practitioners and academics specializing in international law, as well as members of the public sector and the judiciary. The mission of the RFDI is to promote francophone study and research in international law. It collaborates with academic institutions throughout the Francophonie.

Félicitations à Stéphanie Desjardins qui a été élue comme administratrice du Conseil d’Administration du Réseau Francophone de Droit International (RFDI), et selectionnée pour assurer le poste de trésorière du Bureau!

Le RFDI est une association qui rassemble de nombreux internationalistes des milieux académique et professionnel, de même que des membres de la fonction publique et de la magistrature. Le RFDI a pour objectif de promouvoir l’étude et la recherche francophones en droit international. Il collabore avec de nombreuses institutions attachées au monde universitaire et à la Francophonie.

Canada Expands Sanctions Against Russia to Include the Provision of Services to Russian State and Russians

On June 6, 2022, Canada announced a new round of sanctions against Russia imposed under the Special Economic Measures Act by way of amendment to the Special Economic Measures (Russia) Regulations (“Russia Regulations”).

The June 6, 2022 amendments to the Russia Regulations “impose a ban on the export of 28 services vital for the operation of the oil, gas and chemical industries, including technical, management, accounting and advertising services.” Furthermore, the “banning of the exportation of oil, gas and chemical services targets an industry that accounts for about 50% of Russia’s federal budget revenues.”

The new amendments make it illegal for any Canadian or person inside of Canada “to provide to Russia or to any person in Russia any” of the following services:

1. Construction work
2. Retail sales of motor fuel
3. Sales on a fee or contract basis of fuels, metals, ores, timber, building materials, and industrial and technical chemicals
4. Wholesale trade services of solid, liquid and gaseous fuels and related products
5. Retail sales of fuel oil, bottled gas, coal and wood
6. Repair services of personal and household goods
7. Other lodging services not elsewhere classified
8. Transportation of petroleum and natural gas
9. Water transport services – Freight transportation
10. Water transport services – Towing and pushing services
11. Bulk storage services of liquids or gases
12. Leasing or rental services concerning machinery and equipment without operator
13. Computer and related services
14. Research and development services
15. Accounting, auditing and bookkeeping services
16. Market research and public opinion polling services
17. Management consulting services
18. Services related to management consulting services
19. Architectural services
20. Engineering services
21. Integrated engineering services
22. Related scientific and technical consulting services
23. Technical testing and analysis services
24. Advertising services
25. Services incidental to mining
26. Repair services incidental to metal products, machinery and equipment
27. Services incidental to energy distribution
28. Seward and refuse disposal, sanitation and other environmental protection services.

In relation to any of the following industries:

1. Mining of coal and lignite
2. Extraction of crude petroleum and natural gas
3. Mining of metal ores
4. Other mining and quarrying
5. Mining support service activities
6. Manufacture of coke and refined petroleum products
7. Manufacture of chemicals and chemical products

Our team will continue to monitor the sanctions measures related to Russia and Ukraine, providing updates to keep clients informed about important developments affecting trade and services. The lawyers at Tereposky & DeRose have significant experience in the design and implementation of sanctions-related compliance programs, including policies, procedures, employee training, and internal control mechanisms. They also regularly assist both Canadian and international businesses, financial institutions, and individuals with internal investigations when “red flags” appear and provide advice on compliance in these areas. Where breaches have occurred, they have worked closely with their clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.

Vince DeRose
613.237.8862
vderose@tradeisds.com

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Peter Knowlton
613.237.4742
pknowlton@tradeisds.com

Canada Expands Sanctions to Include Additional Individuals and Entities

On May 31, 2022, Global Affairs Canada announced a new round of sanctions against Russia imposed under the Special Economic Measures Act by way of amendment to the Special Economic Measures (Russia) Regulations (“Russia Regulations”). Global Affairs Canada indicated these sanctions are intended to exert further pressure on the Russian regime in response to President Vladimir Putin’s ongoing invasion of Ukraine.

The amendments (which entered into force on May 27, 2022) to the Russia Regulations add twenty-two individuals and four entities. The additions are described by Global Affairs Canada as “senior officials of Russian financial institutions and their family members, as well as key financial institutions and banks.”  Those financial institutions and banks are:  Management Company of the Russian Direct Investment Fund JSC; RVC Management Company LLC; Russian Agricultural Bank JSC; and Investtradebank JSC.

Our team will continue to monitor the sanctions measures related to Russia, Belarus, and Ukraine, providing updates that may impact Canadian business operations. The lawyers at Tereposky & DeRose LLP have significant experience in assisting clients with navigating the parameters of sanctions as well as the design and implementation of sanctions-related compliance programs, including policies, procedures, employee training, and internal control mechanisms. They also regularly assist both Canadian and international businesses, financial institutions, and individuals with internal investigations when “red flags” appear and provide advice on compliance in these areas. Where breaches have occurred, they have worked closely with their clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.  We also regularly assist clients with the application for delisting process as well as applications for exemption permits.

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Vince DeRose
613.237.8862
vderose@tradeisds.com