Canada has announced further amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). The first round of sanctions and additional export prohibitions were announced on June 13, 2024, effective June 12, 2024. The second round of sanctions was announced on June 18, 2024, effective June 13, 2024.

The first round of sanctions adds 11 individuals and 16 entities to Schedule 1 of the Regulations with Canada identifying their involvement in disinformation and propaganda operations, Russia’s military-industrial complex, and sanctions circumvention. These amendments also place export prohibitions under Schedule 7 of the Regulations on an additional 5 categories of goods related to computer numerically controlled machine tools that Russia could use in the production and manufacturing of weapons. These prohibitions prohibit persons in Canada and Canadians abroad from providing these items to Russia.

The second round of sanctions adds 13 individuals to Part 1.1 of Schedule 1 in response to the “death of imprisoned Russian opposition leader Alexei Navalny and Russia’s continued gross and systemic violations of human rights”. Global Affairs Canada stated that the targeted individuals are “senior officials and high-ranking employees of Russia’s investigation agency, penitentiary service and police force who were involved in the ill-treatment and death of Mr. Navalny”.

Our team will continue to closely monitor the sanctions related to Russia, providing updates to keep clients informed about important developments affecting trade and services. We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minster of Foreign Affairs in response to those applications for delisting. We also regularly assist with applications for exemption permits, including under the Special Economic Measures (Russia) Permit Authorization Order. 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.

Authors: Michelle Folinas and Arian Jetoni

Should you have any questions regarding these developments or sanctions generally, please contact: