Canadian sanctions in response to Russian military actions against Ukraine

The Government of Canada has recently announced a series of new economic sanctions in response to Russia’s continuing military actions against Ukraine. These measures have been enacted through amending regulations adopted under the Special Economic Measures Act (SC 1992, c. 17), which came into force on February 24 and February 28, 2022.

The measures build upon Canada’s existing economic sanctions against Russia enacted through the Special Economic Measures (Russia) Regulations (SOR 2014-58) and the Special Economic Measures (Ukraine) Regulations (SOR 2014-60), which were initially adopted in 2014 in reaction to Russia’s actions in the Crimea region of Ukraine. The existing measures already imposed heavy restrictions on dealings between Canadians and certain Russian individuals and entities considered to be instrumental to Russia’s actions in the region. The regulations also severely limited transactions in goods and equipment used in activities relating to offshore oil, shale oil, or Arctic oil exploration and production.

The latest round of economic sanctions expands on the existing asset freeze and wide-ranging ban on dealings between Canadians and Russians to include more than 500 individuals and entities. Sanctioned individuals include Russian President Vladimir Putin and persons considered to be key members of his entourage, as well as family members or close associates, members of the Russian Security Council,  and other individuals and entities deemed to have contributed or supported Russia’s actions in Ukraine.

The list of sanctioned entities in the Special Economic Measures (Russia) Regulations was also expanded to include a number of important Russian banks, financial institutions and public organizations. These include some of Russia’s largest financial institutions, as well as the Central Bank of the Russian Federation, and the Russian Ministry of Finance. These entities are now subject to the asset freeze and general ban on dealings, as opposed to previously existing measures which were for the most part limited to transactions relating to financing and sovereign debt.

The Special Economic Measures (Ukraine) Regulations have also been amended to expand the existing prohibition on dealings in the Russian-occupied Crimea region of Ukraine to include the Russian-controlled Donetsk and Luhansk regions.

In addition to the above-mentioned measures under the Special Economic Measures Act, the Government of Canada has also announced a number of additional sanctions and restrictions against Russia. As of March 3, 2022, these include:

• The cancellation, effective February 24, 2022, of most existing export permits to Russia and suspension of new export permit applications
• A ban on Russian aircraft from entering Canadian airspace, effective February 27, 2022
• A ban on Russian-owned or registered ships and fishing vessels in Canadian ports and internal waters, officially announced on March 1, 2022 and expected to come into effect in the coming days and
• The revocation of “most-favoured nation” status for Russia and its ally Belarus and imposition of customs tariffs of 35 percent on any imports from these two countries to Canada, officially announced on March 3, 2022 and expected to come into effect in the coming days.

Any businesses dealing with Russian individuals or entities should carefully review their ‎operations and ensure that they are maintaining strict compliance with these requirements, and ‎any further sanctions and restrictions that may follow in the coming days, weeks and months.‎

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