New Russia Sanctions: 15 Individuals, 3 Courts

Summary#

These final regulations, SOR/2023-184, amend the Special Economic Measures (Russia) Regulations to add targeted entries to Canada’s Russia sanctions list. The rule adds 15 individuals and 3 courts and came into force on August 17, 2023.

What it does#

• Adds 15 named individuals (Russian justice and security officials) and 3 courts — the Basmanny District Court of Moscow, the Khamovnicheskiy District Court of Moscow and the Moscow City Court — to Schedule 1 of the Special Economic Measures (Russia) Regulations.
• Imposes the Regulations’ broad dealings ban on those listed. That means most people in Canada and Canadians abroad are prohibited from dealing with the listed people or entities, from handling their property, or from providing services to them.
• Makes the new listings part of the Consolidated Canadian Autonomous Sanctions List so banks and other institutions can screen for them.
• Notes the regulations apply from their registration date (they took effect on August 17, 2023) and were published in the Canada Gazette on August 30, 2023.

Who's affected#

• The newly listed individuals and the three Moscow courts added to the sanctions list.
• Canadian banks and other financial institutions that must update screening and block prohibited transactions.
• Canadian businesses, service providers, or individuals who might otherwise do business with the listed people or courts; permit applicants for exemptions could face extra paperwork.
• Law enforcement and border agencies, including the Royal Canadian Mounted Police and the Canada Border Services Agency, which enforce these measures.
• For most Canadians and most Canadian businesses, the government says direct impacts are likely small because these listed people have limited links with Canada.

Why it matters#

• Practically, the change freezes the listed people’s Canadian assets and cuts their access to the Canadian financial system. It also makes it illegal for Canadians to do most business with them.
• Breaking the rules can carry penalties: on summary conviction a fine of up to $25,000 or up to one year in jail (or both), and on indictment imprisonment of up to five years.
• The measure signals Canada’s condemnation of human rights abuses linked to the Russian authorities and aligns Canadian sanctions with those of allies. For most people in Canada it will have little direct effect, but it matters for banks, lawyers, and anyone involved in international transactions or compliance.