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

June 7, 2022

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.


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