Canada Imposes Another Round of Sanctions on Russia in Response to the War in Ukraine

On February 28, 2022, Canada imposed another round of sanctions on Russia in the wake of its invasion of Ukraine. The new sanctions, the key elements of which are described below, are now effective. They were imposed under the Special Economic Measures Act by way of amendment to the Special Economic Measures (Russia) Regulations (the “Russia SEMA Regulations”). Our earlier blog post describes the prior round of sanctions introduced on February 24, 2022.

Russia SEMA Regulations

The February 28, 2022 amendments to the Russia SEMA Regulations add the following:

1. 18 more individuals were added to the to the list of individuals that are subject to a general dealing prohibition, including Vladimir Putin, Sergei Shoigu and Sergei Lavrov – respectively the President, Minister of Defence and Minister of Foreign Affairs of the Russian Federation.
2. Three entities that were in the February 24, 2022 round of sanctions made subject to a prohibition on new debt financings of any term were instead on February 28, 2022 made subject to a general dealing prohibition in an apparent rapid (4-day) rethink of policy. These entities are:
   1. Central Bank of the Russian Federation;
   2. National Wealth Fund of the Russian Federation; and
   3. Ministry of Finance of the Russian Federation.

The February 28, 2022 amendments also added the Bank of Canada to the list of Canadian entities that are required to determine on a continuing basis whether they are in possession or control of property owned or controlled by or on behalf of a designated person who is subject to a general dealing prohibition (including for example the Central Bank of the Russian Federation). This is significant because the Bank of Canada is the first public sector entity to be made subject to this requirement.

Further Sanctions on Russia?

Canada has announced intentions to impose further sanctions on Russia, including banning Russian-owned or registered ships and fishing vessels from Canadian ports and internal waters.

Conclusion

Canada has imposed another round of sanctions on Russia. Additional persons are subject to general dealing prohibitions. Further Canadian sanctions on Russia are likely. Canadian businesses must comply with economic sanctions laws, including these new sanctions.