On February 17, 2015, Prime Minister Stephen Harper announced
new Canadian sanctions against 37 Russian and Ukrainian
individuals, and 17 Russian and Ukrainian entities. These new
sanctions were introduced in response to escalating violence,
including the attacks on the Ukrainian city of Mariupol on January
24. Canada's new sanctions align in part with the European
Union's sanctions against 19 individuals and 9 entities
announced earlier this week.
These latest amendments bring Canada's total number of
sanctioned parties under its Russia and Ukraine sanctions to 273.
Canadian companies doing business abroad should be reviewing their
screening protocols to ensure that they remain in compliance with
All of the newly listed entities and individuals, with the
exception of Rosneft (discussed further below), are subject to
broad sanctions measures. Persons in Canada and Canadians outside
of Canada are prohibited from engaging in any dealings involving
these parties, including facilitating transactions involving their
property, providing financial or related services to them or for
their benefit, or making goods available to them.
Of the 17 newly listed entities, two are Russian and 15 are
Ukrainian. The majority of these listings target armed non-state
actors operating in eastern Ukraine, such as the Kalmius Battalion
or the so-called "Death Battalion." The Russian public
movement Novorossiya, or "New Russia," headed by a
Russian intelligence officer that ostensibly provides humanitarian
aid in eastern Ukraine, is also subject to the new sanctions.
Two companies have also been listed:
Profaktor TOV, an accounting, auditing and bookkeeping firm in
Ukraine, had been previously listed by the United States due to
dealings of its CEO Petr Savchenko in Donetsk. Profaktor is now
listed under the Russia Regulations, but Savchenko is not.
Rosneft, Russia's largest state-owned oil company, is now
listed on Schedule 3 of the Russia Regulations. Although it is not
subject to the broad restrictions described above, there is now a
prohibition against dealing in any new debt of longer than 90
days' maturity in relation to Rosneft, its property, or any
interests or rights in its property.
Of the 37 newly listed individuals, 11 are Russian and 26 are
Ukrainian. The Ukrainian individuals are largely political and
military leadership within the separatist republics of Donetsk and
The Russian individuals are primarily members of the political
and military elite and include:
Anatoly Ivanovich Antonov, and Arkadii Viktorovich Bahkin, both
Deputy Ministers of Defence;
Iosif (Joseph) Davydovich Kobzon, a popular singer and a member
of the State Duma,
Dmitry Konstantinovich Kiselyov, the head of the Russian
Federal State news agency;
Lt. Gen. Igor Nikolaevich Turchenyuk, the commander of Russian
ground forces in the Crimea;
Rear Admirals Valery Vladimirovich Kulikov and Alexander
Mihailovich Nosatov, both listed as the Deputy Commanders of the
Black Sea Fleet; and
Aleksandr Zaldastanov, the leader of the politically
influential Night Wolves Motorcycle Club.
Only one Russian businessperson of note is listed in these
latest amendments: Sergey Chemezov, a known associate of President
Putin's, and CEO of Rostec, a state-owned conglomerate. Rostec
itself has not been listed under Canada's sanctions
Trade Control Compliance
Today's listings by Canada, along with recently intensified
enforcement efforts by the Canada Border Services Agency, the Royal
Canadian Mounted Police and authorities in other jurisdictions,
highlight the need for careful due diligence in conducting business
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), the Central African Republic, Côte
d'Ivoire, Cuba, the Democratic Republic of the
Congo, Egypt, Eritrea, Guinea, Iran, Iraq, Lebanon, Liberia,
Libya, North Korea, Pakistan, Russia, Somalia, South Sudan, Sudan,
Syria, Tunisia, Ukraine, Yemen 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.
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