Belarus: Aviation Insurance and Export Restrictions

Summary#

These are final amendments to the Regulations Amending the Special Economic Measures (Belarus) Regulations: SOR/2022-75. They add new people to Canada’s Belarus sanctions list, ban more aviation insurance, and stop exports of certain goods and technologies to Belarus. The changes came into force on the day they were registered (April 5, 2022) and were published in the Canada Gazette on April 27, 2022.

What it does#

• Adds a new definition of “technology” and updates some wording in the regulations.
• Adds 9 individuals to the sanctions list (newly listed people are described as oligarchs, associates and senior military officials).
• Extends the ban on insurance and reinsurance to explicitly cover aviation and aerospace items and related technology, including goods in Chapter 88 of the Harmonized System.
  • Existing aviation insurance remains valid for 30 days after this section came into force.
• Creates a new prohibition against exporting, selling, supplying or shipping any good, and against providing any technology, if the item appears on the Restricted Goods and Technologies List.
  • The Restricted Goods and Technologies List is prepared by Global Affairs Canada and published on its website.
• Lists several specific exceptions to the export ban, including:
  • temporary media equipment, items for international nuclear safeguards, items for government departments of Canada or partner countries (a list of partner countries is added), activities related to chemical weapons inspections, items for the International Space Station, certain software updates for civilian end users, temporary movements of civil aircraft, and personal effects.
• Tightens the rule that prohibits helping others to carry out activities already banned by the regulations.
• Enforcement and compliance remain the responsibility of the Royal Canadian Mounted Police (RCMP) and the Canada Border Services Agency (CBSA).

Who's affected#

• People and entities in Belarus, including the newly listed individuals and entities that deal with them.
• Canadian insurers and reinsurers that provide aviation or aerospace coverage.
• Canadian exporters, manufacturers and suppliers of items that may appear on the Restricted Goods and Technologies List.
• Airlines and aircraft operators that rely on Canadian insurance markets or that export/import aviation-related goods.
• Canadian banks and other financial institutions that must screen for listed individuals.
• Enforcement agencies such as the RCMP and the CBSA.
• It is unclear exactly how many Canadian businesses will be affected; Global Affairs Canada says the items on the restricted list will be published online to help companies check compliance.

Why it matters#

• The insurance ban makes it harder for Belarusian aviation and aerospace operators to get coverage. Without insurance, many commercial and private aircraft cannot operate internationally.
• The export and technology bans aim to block military‑use and dual‑use items from reaching Belarus. That can reduce Belarus’s ability to support military activity.
• The measures align Canada with partners and add economic pressure tied to Belarus’s support for Russia’s invasion of Ukraine.
• Businesses will face extra compliance checks and may lose or forgo sales to Belarus. The government estimates the products on the list made up about $1.1 million of Canadian exports to Belarus in 2021 (around 6.9% of exports to Belarus).
• Penalties for knowingly breaking the sanctions include fines of up to $25,000 and jail time (up to one year on summary conviction, or up to five years on indictment).