New Russia Sanctions: 33 Individuals, 6 Entities

Summary#

These are final amendments to the Special Economic Measures (Russia) Regulations that add a group of people and organizations to Canada’s Russia sanctions list. The changes took effect on the day they were registered — December 7, 2022 — and impose a broad ban on dealings with the newly listed targets.

What it does#

• Adds 33 individuals and 6 entities to Schedule 1 of the Special Economic Measures (Russia) Regulations. Those listed are described as senior officials and federal institutions tied to human rights abuses inside Russia.
• Creates a new part of the schedule called “Entities — Gross Human Rights Violations” to list the federal bodies added.
• Renames and renumbers several sections and headings in the regulations to keep cross-references consistent.
• Makes the names of the newly listed targets available online and adds them to the Consolidated Canadian Autonomous Sanctions List for compliance and enforcement.
• Confirms enforcement and penalties under the Special Economic Measures Act for breaking the rules (see “Why it matters” for penalty amounts).

Who's affected#

• The 33 individuals and 6 entities added to the sanctions list — mainly current or former Russian officials and federal institutions involved in investigation, detention or prosecution of people opposing state policies.
• Canadian banks and financial institutions, which must update monitoring systems to screen for the newly listed names.
• Canadian businesses or people who would otherwise seek to do business, provide services, or transfer funds to the listed persons or entities. Such dealings are now broadly prohibited unless a permit is granted.
• Enforcement agencies, including the Royal Canadian Mounted Police and the Canada Border Services Agency, which will handle compliance and investigations.

Who is not clearly affected

• The amendments say most listed targets likely have limited links to Canada. The measure is therefore expected to have small direct impact on most Canadians and on small businesses.

Why it matters#

• The practical effect is an asset freeze and a near-total ban on business, financial, and service dealings between Canadians (and people in Canada) and the newly listed individuals and entities. That restricts their access to Canada’s financial and commercial systems.
• The amendments are aimed at punishing and signaling disapproval of what the government calls gross and systematic human rights violations in Russia tied to repression of protest and opposition.
• These listings align Canada with similar actions by allies. They add to prior measures: Canada had already sanctioned over 1,500 people and entities and announced various support packages for Ukraine (including over $600 million in assistance and up to $1.45 billion in IMF loan resources).
• Penalties for knowingly breaking the regulations include a fine of up to $25,000 or imprisonment for up to 1 year on summary conviction, and up to 5 years on indictment.

If anything here is unclear in the official text (for example, the specific activities that triggered each individual listing), the regulations themselves and the public Consolidated Canadian Autonomous Sanctions List are the authoritative sources.