On April 11, 2023, Canada announced new sanctions targeting Russia and Belarus. These sanctions, effective retroactively as of April 5, 2023, are intended to “maintain pressure on the Russian regime”. The announcement coincides with a meeting between Prime Minister Trudeau and the Prime Minister of Ukraine, Denys Smyhal, which was held in Toronto yesterday.

The recent amendments to the Special Economic Measures (Russia) Regulations target individuals and entities providing military services and technology, including 14 individuals who are “largely senior management at Russian companies that provide military services to Russia”, and 34 entities who are “largely military technology and logistics companies”.

Canada’s amendments to the Special Economic Measures (Belarus) Regulations target 9 entities to “further pressure Putin’s enablers in Belarus”. These newly sanctioned entities are “Russian and Belarussian-owned banks in Belarus not previously sanctioned by Canada”. In addition to this latest round of sanctions, Canada has amended sections 3.1 and 3.2 of the Belarus Regulations “to provide greater legal clarity”. The changes include removing reference to specific Belarusian entities and replacing them with broader language to include any entities controlled by Belarus.

Our team will continue to closely monitor the sanctions related to Russia and Belarus, providing updates to keep clients informed about important developments affecting trade and services. 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, including under the Special Economic Measures (Russia) Permit Authorization Order.