On Friday, December 19, 2014, the Government of Canada announced
amendments to the Special Economic Measures (Russia)
Regulations to impose product-specific restrictions on the
supply of certain goods to Russia’s oil sector, specifically
with respect to deepwater, Arctic, and shale exploration and
production. The prohibitions apply to any person or entity in
Canada or by any Canadian person or entity outside of Canada. The
amendments mark the first product-specific restrictions under
Canada’s Russia sanctions regime and are similar to
prohibitions being imposed by the United States and the European
Goods that are listed on the new Schedule 4 to the regulations
cannot be exported, sold, supplied or shipped to Russia or any
person in Russia, nor can any financial, technical, or other
services related to the goods be so supplied, where the goods are
to be used in any of the following applications:
offshore oil exploration or production at a depth of greater
oil exploration or production in the Arctic; or
shale oil exploration or production.
The prohibition covers a wide range of oil industry products,
including various pipe, pumps, drills and boring tools, machinery,
parts and technology. A full list of prohibited items, including
corresponding Harmonized System codes, is available on the Department of Foreign Affairs, Trade and
Development (DFATD) website. The prohibition only applies to
new agreements to supply entered into after December 19, 2014;
obligations to supply under previously existing contracts are
Listed goods, technology or related services that are
not “for use in” in any of
the three listed applications are not covered by the prohibition.
However, anyone wishing to supply such products to Russia for other
applications would be well advised to ensure they have adequate
documentation regarding the end use of the goods in order to avoid
export clearance delays.
The amendments also expand the scope of the prohibition on debt
financing to designated persons to include all “bonds, loans,
debentures, extensions of credit, loan guarantees, letters of
credit, bank drafts, bankers’ acceptances, discount notes,
treasury bills, commercial paper and other similar
instruments”. (The prohibition applies to instruments with a
maturity of longer than 30 days or 90 days, depending on which
schedule the designated person is listed on.) The scope of the
prohibition on equity financing was also expanded to capture all
Finally, the amendments add new individuals, mostly senior
members of the Russian State Duma or officials of the
“Donetsk People’s Republic”, to the list of
designated persons under the Special Economic Measures (Russia)
Regulations and the Special Economic Measures (Ukraine)
Regulations with whom it is prohibited for Canadians to engage
in most business dealings. The full list of newly sanctioned
individuals is available on the DFATD website.
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 Mondaq.com.
Click to Login as an existing user or Register so you can print this article.
Canada is a constitutional monarchy, a parliamentary democracy and a federation comprised of ten provinces and three territories. Canada's judiciary is independent of the legislative and executive branches of Government.
The Government of Alberta recently announced a number of policy changes that will impact the Alberta Electricity Market, composed of its generators, transmitters, distributors, retailers, electricity consumers and wholesale electricity market.
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).