On March 14, 2019, Canada announced a new round of targeted sanctions against Russia for its continued involvement in Ukraine, adding 114 individuals and 15 entities to its Russia and Ukraine sanctions regulations.
Canada has cited Russia’s involvement and escalation in the Kerch Strait – an important transit point for ships en route to major Ukrainian export terminals – as a reason for the new sanctions.
The new individuals and entities are added to “Schedule 1” of the Special Economic Measures (Russia) Regulations and the “Schedule” to the Special Economic Measures (Ukraine) Regulations, which makes them “designated persons” subject to the strictest prohibitions under Canadian sanctions law. The sanctions impose asset freezes and dealings prohibitions on designated persons, whereby Canadian individuals and corporations are broadly prohibited from engaging in substantially all trading activities or transactions related to a designated person or property held by a designated person. More specifically, it is prohibited for any person in Canada and any Canadian outside Canada to:
(a) deal in any property, wherever situated, held by or on behalf of a designated person;
(b) enter into or facilitate, directly or indirectly, any transaction related to a dealing referred to in paragraph (a);
(c) provide any financial or other related service in respect of a dealing referred to in paragraph (a);
(d) make any goods, wherever situated, available to a designated person; or
(e) provide any financial or related service to or for the benefit of a designated person.
Canadian persons, in or outside of Canada, that conduct business with Russia should review this expanded list and ensure they are not engaging in any prohibited activities under Canada’s sanctions regulations. The lists of newly sanctioned individuals and entities are available in the Regulations Amending the Special Economic Measures (Russia) Regulations and Regulations Amending the Special Economic Measures (Ukraine) Regulations.