On March 10, 2022, Canada again amended the Special Economic Measures (Russia) Regulations to add 32 defense entities. Most of these entities are owned by the state or have contracts with the Government of Russia. Specifically, Canada has added five individuals who are “current and former senior officials and associates of the regime”. It also, in this round of amendments prohibited any person in Canada and any Canadian outside Canada from importing specific petroleum products listed in a new Schedule 5.
On March 14, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 15 individuals it has classified as “senior officials of the Government of Russia”. These individuals are now subject to broad dealings ban.
The consolidated Regulations, which itemize the prohibitions and provide lists of all the prohibited entities and individuals may be accessed here.
Since February 24, 2022, Canada has sanctioned 540 individuals, 9 individuals for “gross human rights violations”, and 103 Russian entities under the Special Economic Measures (Russia) Regulations.
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.