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.