31 Russian Officials Sanctioned

Summary#

The final regulations add 31 individuals to the Special Economic Measures (Russia) Regulations, meaning those people are now blocked from certain dealings with Canada. The regulations came into force on August 19, 2022.

What it does#

• Adds 31 individuals (mostly senior Russian regional governors and officials) to Schedule 1 of the Special Economic Measures (Russia) Regulations.
• Puts those listed people under a broad dealings ban: people in Canada and Canadians outside Canada are prohibited from dealing in their property, entering into transactions with them, providing services to them, or making goods available to them.
• Requires financial institutions to add the new names to their monitoring systems and adds the names to the Consolidated Canadian Autonomous Sanctions List to help compliance.
• Notes that enforcement involves the Royal Canadian Mounted Police (RCMP) and the Canada Border Services Agency (CBSA).
• Sets criminal penalties for knowing non‑compliance: up to $25,000 or 1 year in jail on summary conviction, or up to 5 years on indictment.
• Flags that businesses may need permits for any otherwise prohibited dealings; this could create small administrative costs for some firms.

Who's affected#

• The 31 named individuals (senior Russian officials and regional governors) — they face frozen dealings with Canada.
• Canadians and people in Canada who might transact with the listed individuals or their property.
• Canadian banks and financial institutions, which must update screening and monitoring systems.
• Canadian businesses that might seek permits to engage in otherwise prohibited transactions.
• RCMP and CBSA, who have enforcement roles.

Why it matters#

• In practical terms, the listing blocks the named officials from using Canada’s financial system or getting services from Canadians. Banks will screen for and stop prohibited transactions.
• It is part of Canada’s coordinated sanctions response to Russia’s invasion of Ukraine and aims to increase pressure on Russian officials by restricting their international economic links.
• For most Canadians, effects will be indirect. But businesses and financial institutions must comply or face penalties, and anyone who deals with these people could be subject to legal risk.