On July 20, 2023, Canada announced new sanctions under the Special Economic Measures (Russia) Regulations (the “Russia Regulations”) targeting individuals and entities associated with Russia’s “military industrial complex” and Russian efforts to “Russify Ukraine’s culture”. The amendments also create additional prohibitions associated with “arms and related material” under section 3.13 of the Russia Regulations. These include prohibitions for the provision of any financial, technical or other services related to the sale, supply, transfer, manufacture, maintenance or use of arms and related material to Russia or to any person in Russia.

The recent amendments were divided in two packages. The first set of amendments targets 20 individuals and 21 entities associated with “private military companies and so-called volunteer organizations” including “Wagner Group figureheads who have been active in both Ukraine and Africa”. It also includes leaders in Russia’s nuclear sector who have “significantly increased the risk of a nuclear incident”.

The second set of amendments targets 19 individuals and 4 entities, including Russian celebrities who have been used to promote the Russian invasion of Ukraine “through music, concerts and other events”. It also targets entities, senior officials in Russia’s cultural sector, and leaders of major museums who have attempted to “impose Russian culture and education in the parts of Ukraine currently under Russia’s temporary occupation”.

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 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.