Ukrainian President Viktor Yanukovych abandoned plans to sign an agreement with the European Union (“the EU”) in November 2013, instead announcing that Ukraine would strengthen ties with Russia and the Commonwealth of Independent States. In response, more than half a million Ukrainians took to the streets to protest. The December 2013 announcement of a deal with Russia including $15 billion in loans and gas subsidies generated a fresh wave of protests, which were suppressed by the Ukrainian government. Activists were beaten, kidnapped and tortured. The Russian government encouraged, and supported, these measures. On three occasions, President Yanukovych flew to Russia to coordinate his actions with President Vladimir Putin.

On February 22, the Ukrainian parliament voted to impeach President Yanukovych. That same night, he fled to Russia. On February 27, 2014 in Simferopol, the capital of the Ukrainian province of Crimea, uniformed and heavily armed men seized government buildings and the provincial parliament. They had removed their insignia and were wearing masks, but their uniforms and equipment strongly suggested that they were Russian soldiers. On February 28, 2014, Russian troops occupied Crimea’s airports and other strategic facilities. Ukraine’s interior minister described it as a “military invasion and occupation”. On March 1, 2014, President Putin asked the Russian parliament for approval to send troops to Ukraine, without limiting the request to Crimea only. Parliament granted his request. By March 2, 2014, Russia reportedly had more than 6,000 troops in Crimea. Ukraine appealed for international help. In response, the G7 suspended preparations for the G8 Summit in Sochi, Russia, scheduled for June 2014. Russia has now deployed significant military forces to the Crimea, beyond the scope of its basing arrangements with Ukraine and in clear violation of Ukraine’s sovereignty and territorial integrity.

On March 17, 2014, the Special Economic Measures (Russia) Regulations (“the Regulations”) came into force in order to respond to the gravity of Russia’s violation of the sovereignty and territorial integrity of the Ukraine.

The Regulations were amended on March 18, 2014 and March 21, 2014 to include additional names.

On April 28, 2014, section 2 of these Regulations was expanded. On May 4, 2014, May 12, 2014 and June 21, 2014, the Regulations were also amended to include additional names.

On July 24, 2014, these Regulations were amended to include additional names.

On August 6, 2014, these Regulations were amended to include additional names.

On September 16, 2014, these Regulations were amended to include additional names, as well as to impose measures that tighten financial restrictions on designated entities in the banking sector.


The Regulations include a list of names of persons for which the Governor in Council considers there are reasonable grounds to believe that they are connected with the Government of Russia, or that they are individuals or entities engaged in activities that directly or indirectly facilitate, support, provide funding for, or contribute to the deployment of Russian armed forces to Crimea in clear violation of Ukraine’s sovereignty and territorial integrity. The Regulations provide a review mechanism to remove names from the schedule upon receipt of an application from a designated person.

The Regulations impose an asset freeze on designated persons. They prohibit persons in Canada and Canadians abroad from:

  • dealing in any property held by or on behalf of a designated person, or facilitating or providing financial or other related services in respect of such a dealing;
  • making any goods available to a designated person; and
  • providing any financial or related services to or for the benefit of a designated person.

Causing, assisting or promoting prohibited activities is likewise prohibited. Some exemptions exist, including for the following:

  • payments made by or on behalf of designated persons pursuant to contracts entered to before their designation, provided the payment is not for their benefit;
  • pension payments to any person in Canada or Canadian abroad;
  • certain transactions in respect of diplomatic missions;
  • transactions to UN agencies, the International Red Cross and Red Crescent Movement, and Canadian NGOs in certain circumstances;
  • transactions necessary for a Canadian to transfer to a non-designated person any accounts, funds or investments held by a designated person when that person became a designated person;
  • financial services required in order for a designated person to obtain certain legal services in Canada; and
  • payments to any person in Canada or any Canadian abroad in respect of loans entered into prior to March 17, 2014.

The Special Economic Measures (Russia) Permit Authorization Order, made pursuant to subsection 4(4) of the Special Economic Measures Act, authorizes the Minister of Foreign Affairs to issue to any person in Canada or any Canadian outside Canada a permit to carry out a specified activity or transaction, or any class of activity or transaction, that is restricted or prohibited pursuant to the Regulations.

Selected Documents

Regulations and Orders made under the Special Economic Measures Act:

Announcements related to the Regulations made under the Special Economic Measures Act:


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