On May 31, 2022, Global Affairs 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”). Global Affairs Canada indicated these sanctions are intended to exert further pressure on the Russian regime in response to President Vladimir Putin’s ongoing invasion of Ukraine.

The amendments (which entered into force on May 27, 2022) to the Russia Regulations add twenty-two individuals and four entities. The additions are described by Global Affairs Canada as “senior officials of Russian financial institutions and their family members, as well as key financial institutions and banks.”  Those financial institutions and banks are:  Management Company of the Russian Direct Investment Fund JSC; RVC Management Company LLC; Russian Agricultural Bank JSC; and Investtradebank JSC.

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