On January 10, 2023, Canada enacted sanctions against four Sri Lankan state officials “responsible for gross and systematic violations of human rights during armed conflict in Sri Lanka, which occurred from 1983 to 2009”. The Special Economic Measures (Sri Lanka) Regulations (“Sri Lanka Regulations”) came into effect on January 6, 2023, and impose a dealing prohibition, effectively an asset freeze, on listed persons.

While Sri Lanka’s civil conflict ended in 2009, Canada’s announcement indicates that “[s]ystemic impunity for human rights abusers in Sri Lanka continues to jeopardize the safeguarding of fundamental human rights, progress on justice for affected populations, and prospects for peace and reconciliation” and that “[d]espite continued calls from Canada and the international community to address accountability, the Government of Sri Lanka has taken limited meaningful and concrete action to uphold its human rights obligations”.

These new sanctions and the enactment of the Sri Lanka Regulations are intended to “send a clear message that Canada will not accept continued impunity for those that have committed gross human rights violations in Sri Lanka”.

The new Sri Lanka Regulations are the latest of a series of actions taken by Canada in response to human rights violations in the world. On December 9, 2022, Canada announced that it is “imposing measures on those complicit in gross and systematic human rights violations in Russia, Iran and Myanmar”. These measures come in the form of sanctions against 67 individuals and 9 entities “that are complicit in human rights violations around the world”:

• Russia: Canada imposed sanctions against 33 individuals and 6 entities under the Special Economic Measures (Russia) Regulations targeting “current or former senior officials” and entities “involved in gross and systematic human rights violations against Russian citizens who protest against the Russian regime’s illegal invasion of Ukraine and anti-democratic policies”.

• Iran: Under the Special Economic Measures (Iran) Regulations (the “Iran Regulations”), Canada imposed sanctions on 22 individuals, including “senior members of the Iranian judiciary, prison system and law enforcement forces, as well as political leaders, such as senior aides to the regime’s Supreme Leader and senior figures in state-directed media outlets”.                      Further sanctions were issued under the Iran Regulations on January 9, 2023. Canada announced additional sanctions against two individuals and three entities who are complicit in activities of the Iranian regime, such as “its brutal repression of brave Iranian voices”, the “crack down  on demonstrations” and the deployment of “propaganda that serves as  a  pretext for its destabilizing activities both domestically and abroad”.

• Myanmar: Canada imposed new sanctions under the Special Economic Measures (Burma) Regulations (the “Burma Regulations”) against 12 individuals and 3 entities “who perform key functions on behalf of the Myanmar military regime, are responsible for democratic reversals, facilitate arms flows to the regime and enable the regime’s violence, including against civilians”. These additional sanctions represent the seventh rounds of sanctions that Canada imposed in response to the military coup from February 2021.

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. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.