Sanctions: DNR and LNR Officials Added

Summary#

These final regulations amend the Special Economic Measures (Ukraine) Regulations to widen who can be sanctioned and to add a large group of people to Canada’s sanctions list. The changes were registered on April 26, 2022 and published in the Canada Gazette on May 11, 2022.

What it does#

• Expands who can be listed under the regulations to include current or former members of the so‑called Donetsk People’s Republic (DNR) and the so‑called Luhansk People’s Republic (LNR), plus their associates, family members, entities they own or control, and senior officials of related entities.
• Adds 203 named individuals to Schedule 1, Part 1 of the Special Economic Measures (Ukraine) Regulations. (The Canada Gazette notice lists each name.)
• Replaces an existing entry (item 143) with a revised listing for Natalya Yurevna NIKONOROVA.
• Makes the amended rules effective on the day they were registered (April 26, 2022).

Who's affected#

• The people added to the sanctions list: officials, council members and senior figures linked to the DNR and LNR, and the associates, family members, and entities covered by the expanded scope.
• Any person or business in Canada, and Canadians abroad, that might hold assets of or deal with those listed. Canadian banks and financial institutions will need to screen for and block prohibited transactions.
• Federal agencies that enforce these measures, including the Royal Canadian Mounted Police (RCMP) and the Canada Border Services Agency (CBSA).
• It is unclear from the notice whether ordinary residents of the DNR/LNR regions are directly affected beyond those named; the rules target listed individuals and related entities.

Why it matters#

• The rules create a practical freeze on the assets of the listed people and generally ban Canadians and people in Canada from doing business with them. That is meant to cut off financial support for those accused of helping undermine Ukraine’s sovereignty.
• These measures align Canada with allies taking similar steps and increase pressure on the DNR/LNR authorities and their supporters.
• For everyday Canadians, the most noticeable effects are likely to be administrative: banks and businesses must check lists and refuse prohibited dealings. There may be small compliance costs.
• Penalties for knowingly breaking the rules include a summary fine of up to $25,000 or imprisonment for up to one year, and on indictment penalties that can include imprisonment for up to five years.