On August 22, 2023, the Government of Canada released new sanctions under Schedule 1 of the Special Economic Measures (Russia) Regulations (the "Russian Regulations"). The sanctions target four individuals and 29 entities connected to Russia's military-industrial complex, financial institutions, and nuclear sector.
These newly targeted individuals include persons identified by Canada to be involved in these sectors, as well as a Russian Armed Forces Colonel who was found guilty by the District Court of The Hague for the downing of Malaysia Airline's MH17 flight, while it flew over Ukraine in 2014.
Newly targeted entities include entities named by Canada as operating in the military-industrial complex, financial institutions, and the nuclear sector. These include entities that Canada considers to be "responsible for developing products for both civil and military use", such as "weapons that were used by the Wagner Private Military Company", as well as "financial entities previously sanctioned by its G7 allies and directly associated with the Putin regime". Canada has also sanctioned the Russian nuclear industry to condemn what it describes as Russia's "recklessness in this sector".
Our team will continue to closely monitor the sanctions related to Russia, providing updates to keep clients informed about important developments affecting trade and services. We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minster of Foreign Affairs in response to those applications for delisting. We also regularly assist with applications for exemption permits, including under the Special Economic Measures (Russia) Permit Authorization Order. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.
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