Belarus Sanctions: Minister Permit Authority

Summary#

The Special Economic Measures (Belarus) Permit Authorization Order (SOR/2020-215) gives the Minister of Foreign Affairs the power to issue permits that allow people or companies to do activities that are otherwise banned under the sanctions on Belarus. The order was registered on October 2, 2020 and published in the Canada Gazette on October 14, 2020.

What it does#

• Authorizes the Minister of Foreign Affairs to issue permits to any person in Canada or any Canadian outside Canada for specified activities or classes of activities that are restricted or prohibited under the Special Economic Measures (Belarus) Regulations.
• The regulations currently target 11 individuals and bar activities such as dealing in property owned or controlled by a listed person or providing financial or related services to a listed person (these are examples from the regulations).
• Notes that businesses seeking permits may face some extra compliance work, but the government expects those costs to be small because Canadian dealings with the newly listed people are likely rare.

Who's affected#

• People and organizations in Canada and Canadians outside Canada who might otherwise be blocked from dealing with the listed Belarusian individuals or their property.
• Canadian banks, businesses, lawyers, or service providers who might seek a permit to carry out a transaction that would otherwise be prohibited.
• The 11 individuals named in the Special Economic Measures (Belarus) Regulations, who are the targets of the sanctions.

Why it matters#

• This order doesn’t change the sanctions themselves. It simply creates a formal way for the government to grant exceptions when there are valid reasons (for example, specific business needs, legal obligations, or humanitarian reasons).
• That matters to any Canadian person or company that unexpectedly needs to complete a transaction involving a listed Belarusian: they can apply for a permit instead of being automatically blocked.
• It also signals how Canada is responding to the events in Belarus (the 2020 election and related rights abuses) while keeping a mechanism to handle special cases.