Canada announced an additional round of sanctions under the Special Economic Measures (Russia) Regulations, SOR/2014-58 (the “Russia Regulations”) on December 12, 2023, effective retroactively as of December 8, 2023.

This new round of sanctions adds 30 Russian nationals to Part 1 of Schedule 1 of the Russia Regulations. According to the news release from Global Affairs Canada, these individuals ran as candidates in the “sham Kremlin-organized ‘elections’ held on September 8 to 10, 2023, in the temporarily occupied territories of Ukraine”. Canada describes these elections as “another violation of Ukraine’s independence, sovereignty and territorial integrity, as well as of the United Nations Charter”. Canada considers that by running for public office, these individuals sought to legitimize Russia’s invasion of Ukraine.

On December 5, 2023, Canada also amended Part 1 of Schedule 6 of the Russia Regulations to “prohibit the direct import of diamond and diamond-related products originating from Russia in-line with G7 commitments”. These amendments also include “necessary changes to the existing luxury export ban and import ban in the Russia Regulations to ensure consistency with the new additions to the import ban on diamond and diamond-related products”. By implementing these amendments, Canada is “ensur[ing] that revenues cannot be generated from Canada that could eventually support Russia’s budget and ongoing violation of Ukraine’s sovereignty and territorial integrity”.

Our team will continue to closely monitor the sanctions related to Russia, providing updates to keep clients informed about important developments affecting trade and services. We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minster of Foreign Affairs in response to those applications for delisting. We also regularly assist with applications for exemption permits, including under the Special Economic Measures (Russia) Permit Authorization Order. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.

Authors: Stephanie Desjardins, Jack Bowness, and Michelle Folinas

Should you have any questions regarding these developments or sanctions generally, please contact: