CANADA IMPOSES ADDITIONAL SANCTIONS AGAINST BELARUS AND THE LUKASHENKO REGIME

Canada has imposed additional sanctions against Belarus under the Special Economic Measures (Belarus) Regulations. These sanctions target 22 Belarusian officials which Canada believes are “complicit in the stationing and transport of Russian military personnel and equipment involved in the invasion of Ukraine” and 16 Belarusian companies “involved in military manufacturing, technology, engineering, banking and railway transportation”.

This additional round of sanctions was announced during Belarusian opposition leader Sviatlana Tsikhanouskaya’s visit to Canada on November 22, 2022, and came into effect on November 17, 2022.

Similar to the previous round of sanctions from June 27, 2022, these new additions intend to target “the Lukashenko regime and its current policies that threaten the security of Ukraine and Ukrainians”.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

MEMBERS OF RUSSIA’S JUSTICE, SECURITY, AND ENERGY SECTORS TARGETED BY A FURTHER ROUNDS OF CANADIAN SANCTIONS

Canada has imposed additional sanctions targeting 23 individuals who Canada believes “are members of the Russian justice and security sectors, including police officers and investigators, prosecutors, judges, and prison officials, involved in gross and systematic human rights violations against Russian opposition leaders”. These sanctions were implemented in response to “the persecution of the brave Russian dissident Vladimir Kara-Murza”, as described in an announcement from Prime Minister Justin Trudeau on November 14, 2022. These sanctions came into effect on November 10, 2022.

These sanctions were announced shortly after Canada announced further amendments to the Special Economic Measures (Russia) Regulations on October 28, 2022 to sanction 35 individuals who Canada believes are “senior officials of energy entities, including those of Gazprom and its subsidiaries” as well as 6 entities involved in the energy sector “involved in Russia’s ongoing violations of Ukraine’s sovereignty and territorial integrity”.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

CANADA IMPOSES A FIFTH ROUND OF SANCTIONS AGAINST THE IRANIAN REGIME

On November 16, the Government of Canada announced additional sanctions in response to Iran’s “ongoing gross and systematic human rights violations and continued actions to destabilize peace and security”, adding six individuals and two entities to Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Iran Regulations”).

Similar to previous rounds of sanctions, these new additions are intended to target “senior officials, prominent regime supporters and entities that have participated in gross and systematic human rights violations in Iran, including brutal crackdowns on protesters and in the regime’s malign activities abroad”.

Designated persons listed in Schedule 1 of the Iran Regulations are subject to a dealings prohibition, which prohibits any person in Canada or any Canadian outside Canada from “dealing” with designated persons. Prohibitions include, for example, dealing in property, wherever situated, that is owned, held or controlled by listed persons or a person acting on their behalf, or entering into or facilitating any transaction related to a prohibited dealing.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

IRAN’S SUPPORT FOR THE RUSSIAN INVASION OF UKRAINE PLACES IT ON CANADA’S SANCTIONS RADAR … YET AGAIN

On October 31, 2022, the Government of Canada announced additional sanctions in response to the Iran’s “ongoing gross and systematic human rights violations and continued actions to destabilize peace and security”, adding four individuals and two entities to Schedule 1 of the Special Economic Measures (Iran) Regulations. Contrary to the last few rounds of sanctions against Iran, Canada announced that these sanctions are because of “Iran’s active support of Russian atrocities in Ukraine through the sale of weapons and the provision of Iranian military personnel to train and assist Russian forces on the use of Iranian weapons”.

These sanctions target senior officials and prominent regime supporters whom the Canadian government says they have reasons to believe have “participated in gross and systematic human rights violations either in Iran or in the regime’s malign activities abroad, including by attacking other states”.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

The Iranian Regime Subject to Additional Sanctions by Canada

On October 19, 2022, the Government of Canada announced additional sanctions in response to the Iranian regime’s “ongoing gross and systematic human rights violations and continued actions to destabilize regional peace and security”, adding 6 individuals and 3 entities to Schedule 1 of the Special Economic Measures (Iran) Regulations. These sanctions target those “that are among the worst offenders that have participated in or enabled gross human rights violations, including against Iranian women, and disseminated propaganda to justify the Iranian regime’s repression and persecution of its citizens”.

This is the third round of sanctions imposed by Canada against the Iranian regime, following the recent additions from October 13, 2022, and the initial round of sanctions from October 3, 2022 in response to the death and detention of Mahsa Amini.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

Russian Propaganda and Disinformation Again Targeted by New Sanctions

On October 17, 2022, the Government of Canada announced additional sanctions targeting 34 individuals and 1 entity “complicit in the dissemination of Russia disinformation and propaganda”, who “help assist the Russian regime in undermining the principles of state sovereignty and are responsible for spreading false narratives that serve as pretexts for the Russian regime’s unjustifiable war”.

The Government of Canada has indicated it intends to continue efforts to counter disinformation associated with Russia’s invasion of Ukraine. The Government of Canada’s response has included to “work with its international partners to detect, correct and call out the Kremlin’s state-sponsored disinformation about Ukraine” and to publish “reliable and accurate information about the situation in Ukraine at home and abroad”.

These new sanctions are made in addition to 29 state-sponsored disinformation and propaganda agents and 15 entities controlled or owned by the Russian government and involved in disinformation efforts announced on July 8, 2022 as identified by the Government of Canada.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

Canada Imposes New Round of Sanctions Against Iran

On October 13, 2022, the Government of Canada announced additional sanctions in response to “the Iranian regime’s systematic human rights violations and ongoing actions that destabilize regional security”. The new sanctions specifically target individuals and entities that “have participated in or enabled gross human rights violations, including against Iranian women, and perpetuated disinformation activities to justify the Iranian regime’s repression and persecution of its citizens”.

A news release from Prime Minister Justin Trudeau on October 7, 2022 indicated that new sanctions would be added following the recent additions from October 3, 2022. Canada announced the imposition of new sanctions on October 13, 2022, adding 17 individuals and 3 entities to Schedule 1 of the Iran Regulations.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com
 
 

New Sanctions Imposed Against Iran in Response to the Detention and Death of Mahsa Amini

On October 3, 2022, the Government of Canada announced new sanctions against Iran through amendments to the Special Economic Measures (Iran) Regulations (the “Iran Regulations”), which came into force in July 2010.

This latest round of sanctions is introduced in response to Iran’s “gross human rights violations that have been committed in Iran, including its systematic persecution of women and in particular, the egregious actions committed by Iran’s so-called ‘Morality Police,’ which led to the death of Mahsa Amini while under their custody”, as well as “ongoing grave breach of international peace and security”, which includes “weapons proliferation and malicious cyber activity” as well as “state-sponsored disinformation to spread false narratives that attempt to justify its policies”. Amendments to the Iran Regulations were made to include persons who have participated in “gross and systematic human rights violations in Iran” as a basis for being subject to sanctions.

On September 23, 2022, the Minister of Foreign Affairs, Mélanie Joly, released a statement saying that “Canada strongly condemns the reprehensible detention and killing of Mahsa Amini [whose] death was a direct result of the systemic and continued harassment and repression of women in Iran”. Canada condemned Iran’s violence against protestors and called on Iran to refrain from committing further acts of violence to their citizens.

Following the statement from the Minister of Foreign Affairs, Prime Minister Justin Trudeau announced, on September 26, 2022, that Canada would be imposing “sanctions on dozens of individuals and entities, including Iran’s so-called morality police”.

Canada announced the imposition of new sanctions on October 3, 2022, adding 25 individuals and 9 entities to Schedule 1 of the Iran Regulations, including “senior Iranian officials and prominent entities that directly implement repressive measures, violate human rights and spread the Iranian regime’s propaganda and misinformation”. These individuals are now subject to a broad dealings ban. The individuals listed in response to gross and systematic violations of human rights are also rendered inadmissible to Canada under section 35(b) of the Immigration and Refugee Protection Act. These new sanctions are made in addition to the 41 individuals and 161 entities who have been previously sanctioned under the Iran Regulations.

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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Michelle Folinas
613.237.1208
mfolinas@tradeisds.com

 

Canada Expands Russia and Ukraine Sanctions Regulations

On September 29, 2022, the Government of Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 43 individuals.  The Government of Canada also further amended the Special Economic Measures (Ukraine) Regulations to add 35 individuals and 1 entity to Schedule 1 of the Regulations. The amendments to the Ukraine Regulations also add new prohibitions that prohibit any person in Canada and any Canadian outside Canada from conducting certain transactions and activities in the Russian-occupied regions of Kherson and Zaporizhzhia in Ukraine. This includes making investments and dealing in goods exported from or destined to these regions.

Our team will continue to monitor the sanctions measures related to Russia, 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.

Vince DeRose
613.237.8862
vderose@tradeisds.com

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com

 

Canada Imposes New Round of Sanctions Targetting Russian Individuals and Defence Sector Entity

On August 19, 2022, Canada announced two rounds of sanctions targeting an additional 62 individuals it describes as “close associates of the Russian Regime complicit in Russia’s invasion of Ukraine.” Canada stated it has imposed sanctions on these individuals because they are “high-ranking Russian government officials, including Russian federal governors and regional heads, their family members, and senior officials of currently listed defence sector entities.”

On the same day, Canada also announced the sanctioning of a “Russian defence entity … for enabling and supporting Russia’s unprovoked and unjustifiable invasion of Ukraine.”

Our team will continue to monitor the sanctions measures related to Russia, 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.

Vince DeRose
613.237.8862
vderose@tradeisds.com

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Peter Knowlton
613.237.4742
pknowlton@tradeisds.com

Individuals and Entities in Russian Defence Sector and Military Targeted by Canadian Sanctions

On August 2, 2022, the Government of Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 43 individuals and 17 entities, which it identified as elites and close associates of the Regime and Russian defence entities. Specifically, Canada has indicated that “these persons include military officials involved in the Bucha massacre and entities in the defence sector directly or indirectly supporting the Russian military.” Of note, many of the individuals were sanctioned a number of months ago by Canada’s allies, including members of the European Union.

Our team continues to monitor the sanctions related to Russia, providing updates 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. We 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, we 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 Canadian application for delisting process as well as applications for exemption permits.

Jennifer Radford
613.237.9777
jradford@tradeisds.com

Vince DeRose
613.237.8862
vderose@tradeisds.com

Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com

CANADA SANCTIONS RUSSIAN MANUFACTURING INDUSTRY

On July 14, 2022, Canada’s latest sanctions against Russia’s industrial manufacturing industry went into effect. Canada had previously announced these sanctions were incoming on July 9, 2022. These sanctions are issued under the Special Economic Measures (Russia) Regulations (“Russia Regulations”).

Canada expanded its existing measures on Russia’s oil, gas and chemical sectors to include industrial manufacturing. Canada’s new sanctions prohibit Canadians and any person in Canada from providing services incidental to Russian manufacturing. Specifically, the sanctions apply to services relating to the manufacturing of basic materials, fabricated metal products, computer electronic and optical products, electrical equipment, machinery equipment, and motor vehicles. The sanctions also prohibit the provision of services in the land and pipeline transport industry. Previously prohibited services under Part 1 of Schedule 8 now also apply to the manufacturing and land and pipeline transport industries.

Importantly, if a Canadian or person in Canada was already providing listed services to the newly listed industries  under a contract that was entered into before July 14, 2022, then a 60-day grace period applies, allowing Canadian businesses to conclude those contracts before September 12, 2022.

Our team will continue to monitor the sanctions related to Russia, providing updates 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.

Vince DeRose
613.237.8862
vderose@tradeisds.com
Jennifer Radford
613.237.9777
jradford@tradeisds.com
Stephanie Desjardins
613.237.8680
sdesjardins@tradeisds.com
Peter Knowlton
613.237.4742
pknowlton@tradeisds.com