Canada expands Belarus sanctions

Summary#

These final rules amend the Special Economic Measures (Belarus) Regulations to add more people and goods to Canada’s Belarus sanctions. They add 13 individuals and 2 entities to the sanctions list, ban certain luxury goods and a range of advanced or dual‑use items, and tighten prohibitions on helping those banned activities. The regulations were registered on June 25, 2022, and some export/import bans take effect 60 days after registration (on August 24, 2022).

What it does#

• Adds 13 named individuals and 2 named entities to Schedule 1. These people and entities are subject to broad dealings bans (assets and financial dealings).
• Expands the list of restricted goods and technologies that cannot be exported or supplied to Belarus. The new lists cover items such as:
  • consumer communication devices (phones, computers and related peripherals and software),
  • advanced computing and sensing equipment (including quantum computing components),
  • advanced manufacturing gear (including certain metal powders and 3D‑printing equipment),
  • metals and parts, vehicles, unmanned aircraft, and some medical/analytical instruments.
• Introduces a ban on exporting many luxury goods to Belarus and on importing some luxury goods from Belarus. The lists use Harmonized System codes for detail (food and drink, tobacco, clothing, jewelry, art, certain vehicles and machinery, etc.).
• Prohibits exports of specific goods that could be used to make weapons or support weapon production.
• Clarifies that it is illegal for anyone in Canada, or any Canadian abroad, to knowingly help or facilitate activities that these rules ban.
• Moves management of the detailed list of restricted goods and partner‑country exemptions into a published “Restricted Goods and Technologies List” maintained by the government (used to identify limited exemptions for media or partner governments).

Who's affected#

• The 13 individuals and 2 entities newly listed. The two entities added to the list are Belramoshservice and Belteleradio Company.
• Belarusian government and military interests that rely on Canadian goods, technology or financial services.
• Canadian exporters and importers who trade with Belarus in the listed luxury items, advanced technologies, metals, machinery, vehicles, drones, or affected components.
• Canadian banks and financial institutions. They must screen and block dealings with listed people and entities and update monitoring systems.
• Travel and transport businesses, freight forwarders, customs brokers and the Canada Border Services Agency where shipments involve covered goods.
• Anyone who knowingly assists prohibited transactions (the rule applies to “any person in Canada and any Canadian outside Canada”).
• It is unclear how the partner‑country exemptions in the published Restricted Goods and Technologies List will be used in specific cases; some limited exemptions exist (for media representatives, government agencies of partner countries, and certain civilian entities).

Why it matters#

• These changes increase pressure on Belarus for its support of Russia’s invasion of Ukraine. The government says the measures are coordinated with allies.
• For most Canadian businesses, practical effects are likely small. The government estimated Canada’s 2021 trade in the newly banned categories was around $44,000 in exports of the listed luxury goods, $430,000 in imports of such luxury goods, about $2 million in exports of goods used to manufacture weapons, and about $13,000 in exports of advanced goods and technologies.
• Financial institutions and businesses that do deal with Belarus will face compliance checks and could need permits for any activities that would otherwise be banned.
• The rules carry penalties for knowing breaches: a fine of up to $25,000, or imprisonment for up to 1 year on summary conviction (or up to 5 years on indictment). Enforcement involves the Royal Canadian Mounted Police and Canada Border Services Agency.
• The measures are targeted (focused on named people, entities and specific goods) so the government says they aim to limit broader harm to ordinary Belarusian citizens while signalling strong political consequences.