New Russia Sanctions: Individuals, Entities, Tech Ban

Summary#

These final amendments to the Special Economic Measures (Russia) Regulations add 6 individuals and 46 entities to Canada’s Russia sanctions list and create a new list of restricted goods and technologies (called Schedule 5.1) that cannot be sent to Russia. The changes came into force on June 25, 2022.

What it does#

• Rewrites the rules that bar people in Canada (and Canadians abroad) from exporting, selling, supplying or shipping goods or technologies to Russia that appear on the Restricted Goods and Technologies List or on Schedule 5.1.
• Adds these six named individuals to the sanctions list: Adam Sultanovich DELIMKHANOV, Mikhail Eduardovich OSEEVSKY, Mikhail Igorevich POLUBOYARINOV, Sergei Alexandrovich MARKOV, Sergey Alexandrovich PAHOMOV, and Denis Gennadievich POPOV.
• Adds 46 entities (mostly Russian defence firms, research centres and manufacturers) to the sanctions list.
• Creates Schedule 5.1, a new, detailed list of restricted goods and technologies. Key categories include:
  • equipment and components for quantum computers and related quantum devices;
  • cryogenic refrigeration systems that keep temperatures below 1.1 kelvin for long periods and related parts;
  • ultra-high vacuum equipment (UHV);
  • high-quantum-efficiency photodetectors;
  • advanced additive manufacturing (metal 3D printing) equipment and metal powders usable with that equipment;
  • high-end microscopes (scanning and transmission electron microscopes, atomic force microscopes) and related detectors;
  • decapsulation tools for semiconductor devices;
  • software for developing, producing or using the above systems, including digital-twin and reliability-determination software;
  • associated technical know‑how and technology needed to develop, produce or use these items.
• The government notes Canadian exports of the listed advanced goods to Russia were more than $16.7 million in 2021.

Who's affected#

• The six named Russian individuals and the 46 entities added to the sanctions list. The entities are mainly in Russia’s defence, research and manufacturing sectors.
• Canadian companies and researchers that make, sell or ship advanced technology listed in Schedule 5.1 — for example, firms involved in quantum computing, cryogenics, advanced 3D printing, high-end microscopy, semiconductors or related software.
• Canadian banks and other firms that must screen transactions and comply with sanctions.
• Enforcement and border agencies: the Royal Canadian Mounted Police and the Canada Border Services Agency will enforce the rules.

Why it matters#

• The changes tighten Canada’s ability to stop high-tech items and know‑how from reaching parts of Russia’s defence and research sector. That is intended to limit Russia’s capacity to develop military or dual‑use capabilities.
• For most Canadian businesses the impact should be limited, but exporters of specialized equipment or software will need to check the new list and may need permits or to stop planned sales to Russia.
• Non‑compliance carries penalties: a fine of up to $25,000 or up to one year in jail on summary conviction, or, on indictment, imprisonment for up to five years.
• If it’s unclear whether an item is covered, affected businesses and researchers should consult the official Consolidated Canadian Autonomous Sanctions List and guidance from Global Affairs Canada.