Canada expands Belarus sanctions

Summary#

These final regulations amend the Special Economic Measures (Belarus) Regulations to expand Canada’s sanctions related to Belarus. They add 24 individuals and 7 entities to the sanctions list, change some technical exceptions on payments and loans, and took effect on registration day December 2, 2021 (published December 22, 2021).

What it does#

• Adds 24 individuals and 7 entities to Schedule 1 of the regulations. The seven entities added include:

  • Tsentrkurort
  • Presidential Sports Club
  • Gardservis
  • BelTechExport
  • Peleng JSC
  • 140 Repair Plant
  • AGAT Electromechanical Plant

• Changes the text of two exceptions so that:

  • Payments that are due under contracts entered into before a person was listed can still be made, provided the payment is not paid to a listed person or someone acting for them.
  • Loan repayments and enforcement of security for loans made before someone was listed can continue, including payments by guarantors.

• Renumbers one subsection for clarity (a technical change to the layout of the rules).

• Confirms the regulations apply from the day they were registered (December 2, 2021), even though they were published later.

• Keeps in place the permit system under which the Minister of Foreign Affairs can authorize specific otherwise‑prohibited transactions.

Who's affected#

• People and businesses in Canada and Canadians abroad who deal with Belarus-linked persons or companies. Banks and other financial institutions will need to update their sanctions screening and compliance systems.

• The 24 individuals and 7 entities named in the schedule. Being listed can block their access to funds and business with Canadians.

• Listed individuals are rendered inadmissible to Canada under the Immigration and Refugee Protection Act.

• Enforcement and penalties:

  • The Royal Canadian Mounted Police and the Canada Border Services Agency are responsible for enforcing the regulations.
  • On summary conviction, penalties include a fine of up to $25,000 and/or imprisonment up to 1 year; on indictment, imprisonment can be up to 5 years.

• It is unclear from the text how broadly Canadian companies will be affected in practice; the government says most Canadian businesses have limited dealings with the newly listed parties.

Why it matters#

• This is an expansion of Canada’s economic and travel restrictions aimed at increasing pressure on Belarus over reported human-rights abuses. It makes certain financial and commercial interactions with the newly named people and firms illegal for Canadians.

• For Canadian banks, exporters and service providers, the change means updating compliance checks to avoid prohibited dealings. For the listed people and entities, it tightens their international financial and commercial options and can bar travel to Canada.

• The measure aligns Canada with actions by other countries and signals continued diplomatic pressure on the Belarusian government.