New Belarus Sanctions Listings

Summary#

The federal government published the final Regulations Amending the Special Economic Measures (Belarus) Regulations (SOR/2023-178). The amendments add people and organizations tied to Belarus to Canada’s sanctions list. The regulations were registered on August 4, 2023 and published in the Canada Gazette on August 16, 2023.

What it does#

• Adds 9 individuals to Schedule 1 of the Belarus sanctions regulations. Examples include Alena Vasilevna Litvina and Alexei Konstantinovich Talai.
• Adds 7 entities, including the Belarus Ministry of Defence and several military manufacturing or technology companies (for example, BelOMO Holding).
• Creates a new part of the schedule called “Entities — Gross Human Rights Violations” and lists the Internal Troops of the Ministry of Internal Affairs of the Republic of Belarus there.
• Applies a “broad dealings ban” to the newly listed names. That means most transactions or business dealings with those listed will be prohibited under the regulations.
• Says the regulations are in force from the day they are registered (see August 4, 2023).

Who's affected#

• The people and organizations added to Schedule 1.
• Canadian banks and other financial institutions, which must screen for the new names and stop or report prohibited dealings.
• Canadian businesses that might have sought permits to do business with these specific Belarusian entities; such permit applications could be affected.
• Enforcement agencies such as the Royal Canadian Mounted Police and the Canada Border Services Agency, which are responsible for enforcing the rules.
• For most Canadians, the impact will be indirect or minor because the listed people and entities likely have limited links with Canada. If that is unclear in a specific case, it will depend on whether there are existing business or financial ties.

Why it matters#

• These changes tighten Canada’s targeted sanctions on Belarus in response to Belarus’s support for Russia’s invasion of Ukraine and to ongoing human rights abuses inside Belarus.
• For people or firms that have any dealings with the added names, the rules mean those dealings are now generally prohibited and could trigger enforcement action. Penalties can include fines (up to $25,000) or jail (up to one year on summary conviction, or up to five years on indictment).
• The move is part of coordinated international sanctions aimed at increasing pressure on Belarus and its supporters. It also marks the three-year anniversary of the disputed August 9, 2020 presidential election in Belarus.
• Practical effects for most Canadians are likely small, but banks and businesses should update compliance checks to reflect the new listings.