Canada: Canada Expands Economic Sanctions Against Russia

Today, Canada expanded its economic sanctions measures in response to recent events in Ukraine and Russia. 11 additional parties, consisting of nine individuals and two companies were added to the list of "designated persons" under the Special Economic Measures (Russia) Regulations (Russia Sanctions Regulations). These new measures focus on close associates and advisors of Russian President Vladimir Putin. They also target two Russian banks – ExpoBank and RosEnergoBank. Another Russian bank, Bank Rossiya, is already subject to Canadian sanctions.

Also today, both the United States and European Union targeted an additional 24 and 15 parties respectively under their economic sanctions measures. Canada still maintains the longest list of sanctions parties under its Russia and Ukraine sanctions measures – it now identifies over 70 parties. Canadian firms doing business abroad or doing business with foreign companies should be carefully reviewing their activities and updating their due diligence and screening procedures to ensure continued compliance with Canadian and other applicable sanctions regimes.

Restrictions on Activities Involving Designated Persons

For our analysis of earlier Russia and Ukraine sanctions measures imposed by Canada, see Canada Imposes Economic Sanctions Against Former Ukrainian Regime: Is Russia Next? and New Canadian Economic Sanctions Measures Target Russian and Crimean Officials.

The revisions to the Russia Sanctions Regulations that add the nine individuals and two banks to the list of designated persons can be found here.

All companies and individuals in Canada and all Canadian companies and individuals outside Canada are prohibited from engaging in a wide range of activities involving designated persons. In the case of the Russia Sanctions Regulations, this includes prohibitions against:

  1. dealing in any property, wherever situated, held by or on behalf of a designated person;
  2. entering into or facilitating, directly or indirectly, any transaction related to such dealings;
  3. providing any financial or other related service in respect of such dealings;
  4. making any goods, wherever situated, available to a designated person; and
  5. providing any financial or related service to or for the benefit of a designated person.

Tips and Traps in Dealing with Designated Persons

Canadian companies doing business abroad, regardless of location, should keep in mind the following when considering the impact of these measures:

  1. because Canada, the United States and the EU do not have identical lists, screen transactions and ongoing business activity against all applicable lists and understand the application of each regime depending upon the jurisdiction of operations and nationalities involved;
  2. understand who owns or controls the entities you are doing business with abroad - they too should be screened against sanctions lists;
  3. the prohibitions apply regardless of where you are conducting business – e.g., business activities involving a company designated under the Russia Sanctions Regulations are prohibited even if they occur entirely outside of Russia, the Ukraine or the surrounding region;
  4. Canadian economic sanctions measures, including the Russia Sanctions Regulations, also prohibit doing anything that causes, assists or promotes, or is intended to cause, assist or promote, any of the restricted activities identified in the particular measure;
  5. federally and provincially regulated financial institutions and service companies 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;
  6. all persons in Canada and Canadian outside Canada are required to immediately report to the RCMP if:
    1. you are in possession or control of property you have reason to believe is owned or controlled, directly or indirectly, by a designated person or by an entity owned or controlled by a designated person; or
    2. you have any information about a transaction or proposed transaction in respect of such property;
  7. there are various exemptions available for certain dealings with designated persons – e.g., in the case of the Russia Sanctions Regulations, there is an exemption for payments made by a designated person that are due under contracts entered into before the person became a designated person, provided that such payments are not made to or for the benefit of a designated person; and
  8. even if there is no exemption available, you may be able to obtain a permit to allow you to proceed - the sanctions measures under the Special Economic Measures Act allow for the Minister of Foreign Affairs to issue a permit for anything that is prohibited under the particular sanctions measure.

Trade Control Enforcement and Compliance

Today's additional designations by Canada, the United States and the EU, along with recently intensified enforcement efforts by the Canada Border Services Agency, the RCMP and authorities in other jurisdictions, highlight the need for careful due diligence in conducting business activities abroad.

At the present time, Canada imposes trade controls of varying degrees on activities involving the following countries (and over 2,000 listed entities and individuals associated with them): Belarus, Burma (Myanmar), Côte d'Ivoire, the Democratic Republic of the Congo, Cuba, Egypt, Eritrea, Guinea, Iran, Iraq, Lebanon, Liberia, Libya, North Korea, Pakistan, Russia, Somalia, Sudan, Syria, Tunisia, Ukraine and Zimbabwe. Any involvement of these countries or any "designated person" in proposed transactions or other activities should raise a red flag for further investigation to ensure compliance with export and technology transfer controls and economic sanctions.

To view original article please click here

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.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.