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In this post, we describe the many sanctions imposed by Canada on Russia and Belarus, and on certain Ukrainians who have supported them, since our previous update on June 22, 2022.
As discussed below, the key points are:
On June 27, 2022, Canada imposed new sanctions on Russia to:
On July 7, 2022, Canada took the remarkable step of designating 29 individuals who are, according to Canada, Russian disinformation and propaganda figures and 15 entities that Canada refers to as involved in disinformation activities. The Russian government likely considers these persons as media figures, albeit state-friendly or controlled. Also designated is a media regulator. Illustrative of the news-media nature of these persons are the names of the entities:
It may be worth noting that the Deputy Prime Minister, who is widely considered to have the policy lead on Canada's sanctions on Russia, was formerly a well-known member of the press who once served as Moscow bureau chief for an international business news organization.
On July 7, 2022, Canada prohibited the import of certain gold products from Russia, including unwrought gold, semi-manufactured gold, gold powder, monetary gold and jewelry made of gold.
For further discussion of the ban on the provision of certain services to certain industries please see our post of June 22, 2022.
On July 29, 2022, Canada designated an additional 43 individuals and 17 entities. These persons include military officials allegedly involved in the Bucha Massacre and entities in the defence sector that, according to the Government of Canada, directly or indirectly support the Russian military.
On June 27, 2022, similar to sanctions previously or contemporaneously imposed on Russia, Canada imposed new sanctions on the Republic of Belarus to:
On the same day, Canada designated 13 senior officials of the Ministry of Defence of the Government of Belarus and 2 Belarusian military entities.
On June 27, 2022, Canada designated 15 former senior officials of the so-called Luhansk People's Republic (LNR) and the so-called Donetsk People's Republic (DNR), and their family members, as well as purported leaders in areas of Ukraine illegally occupied by Russian forces or controlled by Russian-backed proxies.
Even though the Gazprom pipeline turbine controversy is beyond the scope of this post, we would remiss not to mention it for the benefit of our international readers who may not be aware of it or the court application challenging the Canadian government's permit decision allowing for a turbine bound for a Gazprom pipeline to be exported from Canada. Those interested in this issue can find extensive media coverage online.
Canada continues to add to the thicket of sanctions on Russia and Belarus, including sanctions on persons and a variety of other restrictions. This poses an ever-increasing burden on Canadian businesses that must comply with these sanctions. It is important to take care to ensure compliance. We anticipate that enforcement may be more top-of-mind than it has perhaps been in recent years.
The pace of new Canadian sanctions has not yet slackened. Although there is likely a bottomless well of persons and entities who could potentially be designated for involvement in or support of the war in Ukraine, logically there should be an end point for other sanctions, given the extensive sanctions that have been imposed already and the diminishing returns of identifying any remaining areas of commercial relations between Canada and Russia (or Belarus). However, we have not seen that yet and the Canadian government remains creative in finding new sanctions and, we understand, wishes to maintain a leadership role to the extent possible. Stay tuned for more developments.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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