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Canadian Sanctions Related to Russia

Types of sanctions

Asset freeze

Export and import restrictions

Financial Prohibitions

Recent developments

  • 2022-11-10 - Regulations were amended
  • 2022-10-28 - Regulations were amended
  • 2022-10-14 - Regulations were amended
Do you need a permit or certificate?

Prohibitions

Sanctions related to Russia were imposed under the Special Economic Measures Act in order to respond to the gravity of Russia’s violation of the sovereignty and territorial integrity of Ukraine, and grave human rights violations that have been committed in Russia. On March 17, 2014, the Special Economic Measures (Russia) Regulations (“the Regulations”) came into force.

The Regulations were amended on March 19, March 21, April 28, May 4, May 12, June 21, July 24, August 6, September 16, December 19, 2014, February 17 and June 29, 2015, March 18, 2016, March 4 and 15, 2019, March 21 and 29, 2021, February 24 and 28, March 4, 6, 10, 14, 23, and 24, 2022, April 5, 8, and 19, 2022, May 3, 6, 18, and 27, 2022, June 7 and 27, 2022, July 7, 14 and 29, 2022, August 19, 2022, September 29, 2022, October 14 and 28, 2022, and November 10, 2022.

The Regulations impose an asset freeze and dealings prohibition on designated persons listed in Schedule 1, which include both individuals and entities. It is prohibited for any person in Canada and any Canadian outside Canada to:

  • deal in any property, wherever situated, held by or on behalf of a designated person whose name is listed in Schedule 1
  • enter into or facilitate, directly or indirectly, any transaction related to such a dealing
  • provide any financial or other related services in respect of such a dealing
  • make any goods, wherever situated, available to a designated person listed in Schedule 1
  • provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1

The individuals listed in Part 1.1 of Schedule 1 to the Regulations are also inadmissible to Canada under the Immigration and Refugee Protection Act.

The Regulations also impose restrictions on certain sectors, such as the financial and energy sectors. With some exceptions, they prohibit any person in Canada and Canadians abroad from dealing in new debt of longer than 30 days maturity in relation to persons listed in Schedule 2, or 90 days maturity in relation to persons listed in Schedule 3. Additionally, the Regulations prohibit any person in Canada or Canadians abroad from dealing in new securities in relation to persons listed in Schedule 2.

The Regulations prohibit any ship that is registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a designated person from docking in Canada or passing through Canadian waters.

The Regulations also prohibit the export, sale, supply or shipping of goods listed in Schedule 4, to Russia or to any person in Russia for their use in offshore oil (depth greater than 500m), shale oil or Arctic oil exploration and production. This includes a ban on the provision of any financial, technical or other services related to the goods subject to this prohibition.

The Regulations also prohibit the import, purchase or acquisition by any person in Canada and any Canadian outside Canada, of specific petroleum products listed in Schedule 5, from Russia or from any person in Russia.

The Regulations also prohibit any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any good, wherever situated, or to provide any technology, to Russia or to any person in Russia, if it is described in the Restricted Goods and Technologies List.

The Regulations also prohibit any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any luxury good referred to in column 1 of Part 1 to Schedule 6, wherever situated, to Russia or to any person in Russia.

The Regulations also prohibit the import, purchase or acquisition by any person in Canada and any Canadian outside Canada, of any luxury good referred to in column 1 of Part 2 of Schedule 6, wherever situated, from Russia or from any person in Russia.

The Regulations also prohibit any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any good that could be used for the manufacturing weapons referred to in column 1 of Schedule 7, wherever situated, to Russia or to any person in Russia.

The Regulations also prohibit individuals and entities in Canada from providing any and all insurance, reinsurance, and underwriting services for aircraft, and aviation and aerospace products either owned by, controlled by, registered to, chartered by, or operated by entities and individuals resident, incorporated, or domiciled in Russia.

The Regulations also prohibit the provision of any services referred to in column 1 of Schedule 8, to the Russian oil, gas, chemical and manufacturing industries.

The Regulations also prohibit any person in Canada and any Canadian outside Canada from exporting, selling, supplying or shipping any good or technology, wherever situated, to Russia or to any person in Russia if the good or technology is referred to in Schedule 5.1.

The Regulations also prohibit any person in Canada and any Canadian outside Canada to import, purchase or acquire from Russia or from any person in Russia if the good is referred to in column 1 of Schedule 9.

Causing, assisting or promoting prohibited activities is likewise prohibited.

The Regulations provide a review mechanism to remove names from the schedule upon receipt of an application from a designated person.

Exceptions

Exceptions to the asset freeze and dealings prohibition on designated persons listed in Schedule 1 are available for the following:

  • payments made by or on behalf of designated persons pursuant to contracts entered into prior to the coming into force of the Regulations, provided that the payments are not made to or for the benefit of a designated person
  • pension payments to any person in Canada or any Canadian outside Canada
  • transactions in respect of accounts at financial institutions held by diplomatic missions, provided that the transaction is required in order for the mission to fulfill its diplomatic functions under the Vienna Convention on Diplomatic Relations, or transactions required in order to maintain the mission premises if the diplomatic mission has been temporarily or permanently recalled
  • transactions by international organizations with diplomatic status, agencies of the United Nations, the International Red Cross and Red Crescent Movement, or Canadian non-governmental organizations that have entered into a grant or contribution agreement with Foreign Affairs, Trade and Development Canada
  • transactions necessary for a Canadian to transfer to a non-designated person any accounts, funds or investments of a Canadian held by a designated person on the day on which that person became designated
  • financial services required in order for a designated person to obtain legal services in Canada with respect to the application of any of the prohibitions in the Regulations
  • loan repayments made to any person in Canada or any Canadian abroad in respect of loans entered into before the coming into force of the Regulations, enforcement of security in respect of those loans, or payments by guarantors guaranteeing those loans

Permits and Certificates

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. Further information is available on the “Permits and Certificates” page.

Background

In November 2013, the refusal of then-Ukrainian President Viktor Yanukovych to sign a landmark association agreement with the European Union set off major protests in Kyiv, leading to the fall of the Yanukovych government.

In March 2014, Russian forces occupied the Crimean peninsula of Ukraine. Following the unconstitutional “referendum” on March 16, 2014, President Putin signed a treaty purporting to incorporate Crimea into the Russian Federation on March 18, 2014. Canada, along with the international community, continues to condemn Russia’s illegal occupation and attempted annexation of Crimea.

In the wake of the illegal occupation and attempted annexation of Crimea, Russian-backed militants quickly gained control of significant portions of the Donetsk and Luhansk regions of eastern Ukraine, declaring the creation of the ‘Donetsk People’s Republic’ and the ‘Luhansk People’s Republic’. Fraudulent so-called “independence referendums”, initiated by pro-Russian separatists, were held on May 11, 2014, but gained no international recognition. In the months following, violence increased as Russian-backed insurgents clashed with Ukrainian government forces.

Peace agreements were reached at talks held in Minsk, Belarus, in September 2014 and in February 2015. The February ‘Package of Measures’ contains 13 commitments, including: an immediate and complete ceasefire in the Donetsk and Luhansk regions; the full withdrawal of heavy weaponry by both sides; full exchange of prisoners; pullout of all foreign armed formations; and the regaining by Ukraine of control of its border with Russia, amongst other measures.

Russia’s direct military involvement in Ukraine and clear violation of Ukraine’s sovereignty and territorial integrity continue to be a grave concern for the international community.

Furthermore, events within Russia, including the attack and subsequent imprisonment of Russian opposition figure Alexey Navalny, highlight a trend of deepening authoritarianism in the country. International human rights organizations have noted that Russia’s human rights record has continued to deteriorate in recent years.

Russia has continued to play a destabilizing role in Ukraine, while denying that it is even a party to the conflict in the east, thus leading to a deadlock in the peace negotiations. It also continues to violate human rights in an aggressive and systematic fashion.

In August 2020, prominent opposition figure Alexey Navalny was poisoned with a Novichok-type chemical nerve agent, which was almost fatal and required months of recovery in a German hospital. This, followed by his disturbing treatment by the Russian authorities and the subsequent violent suppression and mass detention of his supporters, brought to the fore a pattern by the Russian government of increasing internal repression and targeting opposition voices.

Significant open source evidence makes clear that the attack on Mr. Navalny was undertaken with the involvement of the Russian authorities. Russia continues to deny any involvement in the attack, and has actively promulgated false and contradictory narratives as alternatives. The Russian government has also refused all calls for an investigation into the incident.

Following Mr. Navalny’s return to Russia on January 17, 2021 from his treatment and recovery in Berlin, he was detained for violating the terms of a 2014 suspended jail sentence. The Council of Europe’s Commissioner for Human Rights noted that the judgement “defie[d] all credibility and contravene[d] Russia’s international human rights obligations, adding that the original criminal conviction had been found to be “arbitrary and manifestly unreasonable” by the European Court of Human Rights. Mr. Navalny was then sentenced to two years and nine months in a penal colony for violating the terms of his parole while seeking treatment in Germany. This verdict prompted thousands of protesters to take to the street to demand his release in January 2021. In response, Russian law enforcement violently suppressed the demonstrations and detained over 10,000 people for participating in the protests.

Mr. Navalny is not the only individual to have been targeted by the regime for opposition activities. Russia has a demonstrated history of human rights violations, targeting political opponents and critics, and repressing internal dissent, sometimes violently. International and local human rights groups cite reports of multiple incidents of mistreatment committed by law enforcement and correctional bodies, including physical abuse of detainees at the hands of the police, torture or severe mistreatment of inmates in prison colonies, and detention of individuals for association with opposition organizations.

The Russian government is also using legislative measures to suppress opposition voices. In late December 2020, President Putin signed a large number of bills into law, including restrictions on protests, online information, and on individuals and organizations receiving funds from foreign sources for their activities. Civil society space in Russia has continued to shrink, and legal efforts continue to target human rights defenders, and the media. Aggressive state-driven media campaigns discredit the work of civil society, and attacks on civil society actors, as in previous years, remain frequent.

Recent Developments

Since fall 2021, a significant build-up of troops (est. 150,000-190,000), military equipment, and military capabilities in and around Ukraine has been accompanied by other Russian escalatory behaviour, including hybrid campaign techniques targeting Ukraine. This is in addition to approximately 50,000 Belarusian troops that have been mobilized in early 2022. This aggression directly threatens and imposes significant further costs on Ukraine, and is also a blatant violation of the Minsk Agreements for a peaceful resolution to the conflict in eastern Ukraine.

Diplomatic engagement had been very active in early 2022, including negotiations along several tracks, including via: (1) U.S.-Russia bilateral talks (e.g., the U.S.-Russia Strategic Stability Dialogue); (2) NATO; (3) the OSCE; and, (4) the Normandy Four format (Ukraine, Russia, Germany, France) for the implementation of the Minsk Agreements.

On February 21, 2022, Russia signed a decree recognizing the “independence” and “sovereignty” of the so-called Luhansk People’s Republic (LNR) and Donetsk People’s Republic (DNR) regions. Immediately following the recognition of the so-called LNR and DNR, President Putin ordered Russian forces to perform peacekeeping functions in the regions. On February 22, Russia’s Duma gave President Putin permission to use military force outside the country. Uniformed Russian troops, attack helicopters, and armoured vehicles began moving into the territories for the first time, where only covert forces had been. On February 18, Russia-backed so-called authorities ordered the evacuation of women and children from the region, as well as the conscription of men aged 18 to 55. Self-proclaimed leader of DNR, Denis Pushilin, signed an additional decree on February 22 to admit men aged 55 and over to voluntarily join as well.

On February 24, 2022, without provocation, Russian forces initiated a comprehensive invasion of Ukraine. This egregious step is a blatant violation of international law and the rules-based international order. The attacks have caused widespread devastation of Ukrainian infrastructure and property, and unnecessary deaths of Ukrainians, particularly civilians.

These actions are a continuation and acceleration of the violent steps taken by Russia since early 2014 to undermine Ukrainian security and sovereignty, and have rendered the Minsk Agreements moot.

G7 Foreign Ministers released a statement on February 21, 2022, condemning Russian recognition of the so-called LNR and DNR regions and stated that they were preparing to step-up restrictive measures responding to Russia’s actions, while reaffirming their unwavering commitment to Ukraine’s sovereignty and territorial integrity. G7 Foreign Ministers and NATO leaders continue to be united in promising significant consequences for Russia.

In light of these events, on February 24, 2022, Canada further amended the Special Economic Measures (Russia) Regulations twice. In the first instance, amendments were made in response to the Russian recognition of the independence and sovereignty of Ukraine’s Donetsk so called people’s Republic (DNR) and Luhansk people’s Republic (LNR) regions and added 351 members of the State Duma to Schedule 1, three (3) entities to Schedule 3.1, two (2) entities to Schedule 1, new prohibitions on Russian sovereign debt, and new criteria for listing targets. In the second instance, amendments were made in response to the Russian military attack against Ukraine’s territory in the so called DNR and LNR regions and added 31 new individuals and 19 new entities to Schedule 1 of the Regulations. These are subject to a broad dealings ban. In addition, five (5) entities were moved from Schedule 2 to Schedule 1 and three (3) entities were moved from Schedule 3 to Schedule 1, which resulted in broader prohibitions imposed on these entities.

On February 28, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add eighteen members of the Security Council of the Russian Federation responsible for these actions, including President Vladimir Putin, Foreign Minister Sergei Lavrov, Minister of Defence Sergei Shoigu, Minister of Justice Konstantin Chuychenko, and Finance Minister Anton Siluanov. The amendments also moved three entities from Schedule 3.1 to Schedule 1.

On March 4, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 10 executives in the energy sector, working for the state-owned or controlled oil entities Rosneft or Gazprom.

On March 6, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 10 current or former senior government officials and their close associates, as well as agents of disinformation. Canada also prohibited any ship that is registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a designated person from docking in Canada or passing through Canadian waters.

On March 10, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 32 defense entities, most of which are owned by the state or have contracts with the Government of Russia; to add five (5) individuals who are current and former senior officials and associates of the regime; as well as to prohibit any person in Canada and any Canadian outside Canada from importing specific petroleum products listed in a new Schedule 5.

On March 14, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 15 senior officials of the Government of Russia, who are now subject to a broad dealings ban.

On March 23, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 160 members of the Russian Federation Council, who are now subject to a broad dealings ban. With these names, all members of the Russian Federation Council are now sanctioned by Canada.

On March 24, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the export certain goods and technologies to Russia. The Restricted Goods and Technologies List includes a broad range of items in the areas of electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation. This decision will help to undermine and erode the capabilities of the Russian military.

On April 5, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the provision of all insurance, reinsurance, and underwriting services for aircraft, aviation and aerospace products either owned by, controlled by, registered to, chartered by, or operated by entities and individuals resident, incorporated, or domiciled in Russia. This amendment also listed an additional nine oligarchs and their family members, as well as regime associates.

On April 8, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 33 entities that belong to the defence sector which directly or indirectly facilitate or support the violation of the sovereignty or territorial integrity of Ukraine.

On April 19, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 14 oligarchs, close associates of the Russian regime, and members of their families.

On May 3, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 21 oligarchs, close associates of the Russian regime, and members of their families.

On May 6, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 19 individuals who are senior defence officials and 5 defence entities.

On May 18, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the export of certain luxury goods and goods that could be used in the manufacturing of weapons to Russia, to prohibit the import of certain luxury goods from Russia, and to list an additional 14 oligarchs, close associates of the Russian regime, and members of their families.

On May 27, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 22 individuals who are senior officials of financial institutions and their family members, as well as 4 key financial institutions and banks.

On June 7, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the provision of 28 services to the Russian oil, gas and chemical industries, including technical, management, accounting, and advertising services.

On June 27, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the export of certain advanced technologies and goods that could be used in the production and manufacturing of weapons by Russia, and to list an additional 6 individuals who are senior defence officials and 46 defence entities.

On July 7, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 29 individuals who are Russian disinformation and propaganda figures and 15 entities involved in disinformation activities. Canada also prohibited the import of certain gold products from Russia, including unwrought gold, semi-manufactured gold, gold powder, monetary gold and jewelry made of gold.

On July 14, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to prohibit the provision of 2 manufacturing services to the Russian oil, gas, chemical and manufacturing industries. Canada targeted the manufacturing sector by adding 8 new industries to Schedule 8.

On July 29, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 43 individuals and 17 entities. These persons include military officials involved in the Bucha massacre and entities in the defence sector directly or indirectly supporting the Russian military.

On August 19, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 62 individuals. These persons are listed as senior government officials, including Russian federal governors and regional heads, family members and senior defence officials of previously-listed entities in addition to 1 defence sector entity.

On September 29, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 43 individuals who are family members of already listed oligarchs, additional oligarchs or financial elites.

On October 14, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to list an additional 34 individuals and 1 entity. These individuals and entity are agents of Russian propaganda and their family members, and influential individuals spreading disinformation.

On October 28, 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 35 individuals who are senior executives of energy entities already under sanction and 6 entities involved in the energy sector.

On November 10 2022, Canada further amended the Special Economic Measures (Russia) Regulations to add 23 individuals who are members of the Russian justice and security sector, including police officers and investigators, prosecutors, judges and prison officials, including senior Russian government officials. They have been involved in gross and systematic human rights violations in Russia against opposition leaders, including Vladimir Kara-Murza, Alexey Navalny and other Russian citizens.

Selected documents

Regulations

Regulations and Orders made under the Special Economic Measures Act:

Announcements

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

Related links

Legal advice

Please be advised that Global Affairs Canada cannot provide legal advice to members of the public. For this reason, we cannot deliver an opinion as to whether or not a specific activity or transaction would contravene sanctions legislation. You should consider seeking legal advice in relation to an activity that may contravene a Canadian sanction law.

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