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Canada joins international counterparts in responding to Russia’s “fundamental challenge to the world order” with economic sanctions

Canada has imposed new economic sanctions against Russia in response to its unprovoked and illegal invasion of Ukraine. The Canadian government has described the invasion as an “egregious step” and “a blatant violation of international law and the rules-based international order”. It noted the invasion is “a continuation and acceleration of the violent steps taken by Russia since early 2014 to undermine Ukrainian security and sovereignty, and have rendered the Minsk Agreements moot”.[1] In the words of Canada’s Minister of Foreign Affairs, Mélanie Joly, Russia’s invasion of Ukraine is a “fundamental challenge to the world order that has kept us safe since the Second World War”.[2]

On February 22, 2022, Prime Minister Justin Trudeau announced a “first round” of sanctions, after Russia signed a decree recognizing the independence and sovereignty of the non-government controlled areas of Donetsk and Luhansk. These measures came into effect on February 24, 2022 and listed 351 persons, the members of the Russian Duma (lower parliamentary house), as well as two Russian banks. The Prime Minister described this “first round” as follows:

We will ban Canadians from all financial dealings with the so-called independent states of Luhansk and Donetsk. We will sanction members of the Russian parliament who voted for the illegal decision to recognize these so-called republics. We will ban Canadians from engaging in purchases of Russian sovereign debt, and we will apply additional sanctions on two State-backed Russian banks and prevent any financial dealings with them.[3]

On February 24, 2022, Canada announced a second round of sanctions in response to Russia’s invasion, including restrictions on 58 additional Russian individuals and entities, including banks, financial elites and their families, sanctioning members of the Russian Security Council, imposing restrictions on four Ukrainian individuals for their collaboration with Russia to destabilize Ukraine, and restricting exports of dual-use and other controlled items to Russia by halting the issuance of any new export or brokering permits and cancelling existing permits, with a limited number of exceptions for critical medical supply chains.[4] Canadian export controls appear notably more narrow in scope than those imposed by the U.S., as discussed below.

On February 25, 2022, Canada announced its third round of sanctions, indicating that it would be placing sanctions on Russian President Vladimir Putin, his former chief of staff Sergei Ivanov, and Russian Foreign Minister Sergei Lavrov. Canada further announced that additional sanctions would be applied to Belarus, targeting 57 individuals, for aiding Russia’s invasion of Ukraine.[5] Canada had already suspended the issuance of new export and brokering permits for controlled items to Belarus effective November 2020.[6] On February 27, 2022, Canada closed its airspace to Russian aircraft.[7] 

In imposing these sanctions, Canada has acted in coordination with a number of international allies, including the United States, United Kingdom, and Germany, although there can be significant differences in the substance and application of these measures, including the targeted parties, among the allies’ sanctions programs.

Given the significant participation of Russian businesses, and in particular Russian banks, in the global economy, these sanctions measures are anticipated to have a greater impact than any sanctions program in recent history. Although Russia is not one of Canada’s leading trade and investment partners, annual goods and services flows between the two countries exceed CAD$1.8 billion,[8] Russian foreign direct investment in Canada exceeds CAD$1.7 billion,[9] and Canadian direct investment in Russia totals approximately CAD$3.5 billion.[10] This far exceeds trade and investment with any other country subject to Canadian economic sanctions.

The Revised Sanctions Regulations

Canada has historically been a strong supporter of Ukraine, and was an early adopter of punitive sanctions in response to Russia’s occupation of the Crimea region. Even before the current measures were imposed, Canada had imposed sanctions against more than 440 Russian and Ukrainian individuals and entities determined to be involved in violations of Ukraine’s sovereignty and territorial integrity[11] — a number which now exceeds 850, nearly doubling the reach of Canadian sanctions measures in this region. Our Terms of Trade blog discusses many of these sanctions: see, for example, New Canadian Economic Sanctions Measures Target Russian and Crimean Officials (March 17, 2014), which discusses Canada’s true first round of economic sanctions against Russia. These sanctions have been amended from time to time as there have been further developments in the area.

On February 24, 2022, the Canadian government implemented two new amendments to the Special Economic Measures (Russia) Regulations (the “Russia Regulations”).[12] It also implemented two amendments to the Special Economic Measures (Ukraine) Regulations (the “Ukraine Regulations”),[13] which already feature a number of very broad restrictions that apply to the Crimea region of Ukraine, to expand the territorial restrictions to include the Donetsk and Luhansk regions, as well as additional measures.

As noted above, on February 25, 2022, Canada also announced that additional sanctions would be applied to Belarus, targeting 57 individuals for aiding Russia’s invasion of Ukraine. These amendments have not yet been published, but it appears the amendments will be restricted to the schedules of individuals and entities to whom the sanctions apply in the Special Economic Measures (Belarus) Regulations (“Belarus Regulations”).[14]

A. Amendments to the Russia Regulations

In response to these events, Canada has thus far published two amendments to the Russia Regulations, one in response to Russia’s recognition of the independence and sovereignty of Donetsk and Luhansk[15] and the second in response to Russia’s military attack against Ukraine.[16] Key amendments are as follows:

  • Greatly expanded number of listed persons.
    • Following the recognition of Donetsk and Luhansk, Canada added 351 individuals of Russia’s State Duma who voted in favour of that recognition, as well as two banks, VEB[17] and Promsvyazbank PJSC, to Schedule 1 (to which listed persons the general dealings prohibitions apply).[18] This greatly restricts any potential dealings with such persons and any property owned or controlled (directly or indirectly) by them. As described further below, these banks are also targeted by international sanctions.
    • Following the invasion of Ukraine, Canada added an additional 31 individuals and 27 new entities to Schedule 1.[19] These individuals and entities are “key members of President Putin’s inner circle, close contacts and family members of some individuals already sanctioned by Canada, and 27 key financial institutions”. The listed entities have deep ties to the Russian state and include Russian Railways, theRussian Agricultural Bank, VTB, Gazprom entities, United Aircraft Corporation, Rostec, and Sberbank (upon which expanded sanctions have been imposed).[20]
    • Canada has also added three entities (Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation) to the new Schedule 3.1.[21] As discussed below, the restrictions on these entities are specifically tied to the new debt restrictions introduced in the amendments.
    • On February 25, 2022, Canada announced that it would also be placing sanctions on Russian President Vladimir Putin, his former chief of staff Sergei Ivanov, and Russian Foreign Minister Sergei Lavrov.[22]
  • New prohibitions on Russian sovereign debt.
    • The Russia Regulations now prohibit persons in Canada and Canadians outside of Canada from transacting in, providing financing for, or otherwise dealing in new debt (irrespective of the time for maturity) issued by any person listed in the newly introduced Schedule 3.1 (currently comprising the Russian Central Bank, National Wealth Fund, and Ministry of Finance), or in relation to a person listed in Schedule 3.1 or their property or interests or rights in property.[23] This prohibition expands upon pre-existing debt financing provisions applicable to new debt in relation to other listed entities with longer than 30 days’ maturity and 90 days’ maturity.
  • Expanded the criteria for identifying listed or designated persons.
    • Canada has expanded the list of grounds upon which persons may be designated as listed persons. Now, among other changes, associates and family members of those engaged in activities that facilitate, support, fund or contribute to the violation or attempted violation of the sovereignty or territorial integrity of Ukraine can be listed. Additionally, entities owned, held or controlled, whether directly or indirectly, by Russia or acting on behalf of or at the direction of Russia are now also included, as are their senior officials.[24] (“Russia” is defined as the Russian Federation, including any political subdivision, department or agency thereof.)

B. Amendments to the Ukraine Regulations

In addition to the amendments to the Russia Regulations, Canada has thus far published two amendments to the Ukraine Regulations.[25] The key changes are as follows:

  • Canadians are now banned from all financial dealings with the “so-called” independent states of Donetsk and Luhansk .
    • With respect to the DNR and LNR regions of Ukraine, defined as “the so-called Donetsk People’s Republic and the territory it controls in the Donetsk oblast of eastern Ukraine” and “the so-called Luhansk People’s Republic and the territory it controls in the Luhansk oblast of eastern Ukraine”, the Ukraine Regulations now feature a number of prohibitions impacting most trade and investment activity involving these regions. For example, it is prohibited to make investments involving properties or persons located in the DNR/LNR regions and to provide or acquire financial services related to the same. It is also generally prohibited to import, purchase or acquire goods from these regions or to export to these regions or people within them, and to provide certain services (e.g., technical assistance).[26]
    • Unsurprisingly, these prohibitions are almost identical to and reflect the broadened terms of the Ukraine Regulations’ prohibitions applicable to the Crimea region of Ukraine.
  • Canada added four new individuals to Schedule 1 of the Ukraine Regulations.
    • Four individuals were added to Schedule 1 due to their “collaboration with Russia to destabilize Ukraine”.[27]

C. Upcoming amendments to the Belarus Regulations

As noted above, Canada announced on February 25, 2022 that it will also be placing sanctions on Belarus, targeting 57 individuals, for aiding Russia’s invasion of Ukraine.[28] These amendments have not yet been published, but it appears the amendments will be restricted to the schedules of listed persons. Exports to Belarus continue to be subject to existing controls, discussed below.

Impact of new sanctions listings on Canadian businesses

As a consequence of the amendments, a great number of additional individuals and entities are now listed persons and subject to Canadian sanctions.

The implications associated with current or potential customers, vendors, service suppliers or other business partners or counterparties becoming listed persons under Canadian sanctions laws are significant — the prohibitions essentially preclude persons in Canada and Canadians outside of Canada from engaging in most activities directly or indirectly involving these individuals and entities. In particular, persons in Canada and Canadians outside of Canada are prohibited from dealing in property held by or on behalf of listed persons, entering into or facilitating transactions related to dealings in such property, providing financial or other related services related to dealings in such property, making any goods, wherever situated, available to listed persons, and providing any financial or related service to or for the benefit of listed persons.

Potential violations of Canadian sanctions laws are generally investigated by the Royal Canadian Mounted Police (“RCMP”) and violations may result in criminal charges and prosecution. For the Special Economic Measures Act specifically, the maximum penalty is five years in jail and a fine in an amount as directed by the court.

Canadian financial institutions and other financial service providers, including securities dealers, portfolio managers and investment advisers, also have a “duty to determine”, which requires these institutions to determine, on a continuing basis, whether they are in possession or control of property owned or controlled by or on behalf of a listed person.

Further, any person in Canada and Canadian outside Canada must disclose without delay to the RCMP or the Canadian Security Intelligence Service any: (i) property in their possession or control that they have reason to believe is owned or controlled, directly or indirectly, by a listed person or by an entity owned or controlled by a listed person, and (ii) information about a transaction or proposed transaction in respect of such property.

All Canadian companies doing business abroad should be screening all parties involved in their dealings, and those who directly or indirectly own or control them, against the lists of sanctioned individuals and entities. This is now especially the case for firms whose activities may involve Russia, Ukraine, Belarus, and surrounding regions.

Key exceptions and carve-outs

Canadian sanctions regulations contain a number of grandfathering provisions, which exempt certain types of dealings with listed persons provided they relate to the period prior to the person’s designation or before the regulations or a specific section of the regulations came into force.

For example, paragraph 4(a) of the Russia Regulations provides that the prohibitions do not apply to payments made by or on behalf of listed persons provided the payment is due under a contract entered into prior to the person’s designation and provided that payment is not made to or for the benefit of a listed person. Paragraph 4(g) contains a similar exception for loan repayments relating to loans that predate designation.

The Ukraine Regulations also contain grandfathering provisions. For example, subsection 4.3(1) of the amended regulations provides that sections 4.1 and 4.2 (which set out the new prohibitions on activities in the DNR and LNR regions of Ukraine) do not apply in respect of contracts that predate when those provisions came into force.

Gaps and inconsistencies between Canadian and other sanctions measures

Although attempts have been made by Canada and its allies to coordinate their sanctions measures against Russia, there can be significant differences in the scope and implementation of these measures from one country to another. This is particularly apparent with the list-based sanctions targeting Russian individuals, banks and other entities. Not only can the lists differ but also the prohibitions that apply to a listed person.

For example, as noted below, the United States has imposed limited prohibitions against Sberbank related to correspondent or payable-through accounts and processing of transactions, measures which only come into effect on March 26, 2022,[29] rather than listing Sberbank as a Specially Designated Person subject to blocking or freezing requirements. Canada, on the other hand, has listed Sberbank as a designated person effective February 24, 2022 and subjected any property held by or an behalf of that bank to a freeze. This creates significant gaps in the treatment of Sberbank in each jurisdiction.

Canada also suspends permits for the export and brokering of controlled goods and technology to Russia

On February 24, 2022, Global Affairs Canada released a Notice to Exporters and Brokers – Export and Brokering of items listed on the Export Control List and the Brokering Control List to Russia. Pursuant to this notice, Canada will, effective immediately, cease the issuance of permits for the export or brokering of controlled goods and technology to Russia. The notice also indicates that exporters with valid permits will have their permits immediately cancelled. Exceptions will be considered on a case-by-case basis for permits and applications related to specific end-uses, such as for medical supply and humanitarian needs.

We note that this approach is fairly narrow in scope, as it focuses only on items listed on Canada’s Export Control List. This contrasts with the newly announced export control measures adopted by the United States, discussed further below, which impose prohibitions on sensitive items that Russia relies on for its defense, aerospace, and maritime industries, capturing many items that were previously not subject to export controls when destined for Russia (e.g., semiconductors, computers, telecommunications, information security equipment, lasers, and sensors). This also includes certain items made in other countries using U.S. technology, software or equipment. For more information, please refer to the U.S. Bureau of Industry and Security’s February 24, 2022 notice, which describes its “sweeping series of stringent export controls that will severely restrict Russia’s access to technologies and other items that it needs to sustain its aggressive military capabilities”.

In November 2020, the Canadian government issued a similar notice in respect of Belarus — in that notice, Global Affairs Canada indicated that it would suspend the issuance of all new permits for the export and brokering of controlled goods and technology to Belarus. Unlike the case for previously-issued permits to Russia, in the case of Belarus, exporters who were issued permits prior to the date of the notice could continue to export against those permits during their validity.[30]

Canada acts in parallel with its international counterparts

Canada acted in coordination with the other Group of Seven members, and the European Union, in imposing sanctions and export controls against Russia.

United States

The United States announced a “first tranche” of measures on February 22,[31] followed by an updated list on February 24,[32] targeting major Russian banks and the tech sector and members of the Russian elite close to Putin, many of whom serve in targeted entities, and the further addition of sanctions on Putin and key ministers and military leaders responsible for the invasion:

  • Correspondent and payable-through account sanctions on Sberbank and its 25 subsidiaries, which restrict its ability to engage in US dollar transactions and the international market;
  • Full blocking sanctions on VTB Bank (Russia’s second largest financial institution), VEB (Vnesheconombank), the servicer of Russia’s sovereign debt, PSB (the Russian state defence bank), Bank Otkritie, Sovcombank OJSC, Novikombank and their 54 subsidiaries, which freeze bank assets touching the US financial system and prohibiting US persons from dealing with them;
  • Debt and equity restrictions on thirteen key Russian enterprises and entities, including Sberbank, Gazprom and related entities Gazprom Neft and Gazprombank, Transneft, Rostelecom, RusHydro, Alrosa, Sovcomflot, and Russian Railways, as well as several other banks, preventing them from raising funds through the US market;
  • Full blocking sanctions on Vladimir Putin, as well as key ministers, military leaders, and individuals with close ties to Putin, including:
    • Sergei Lavrov, Minister of Foreign Affairs;
    • Sergei Shoigu, Minister of Defence;
    • Valery Gerasimov, Chief of the General Staff of the Armed Forces;
    • Sergei Sergeevch Ivanov, chief executive of Alrosa and board member of Gazprombank, and his father, Sergei Borisovich Ivanov, Putin’s former chief of staff;
    • Petr Fradkov, chair and chief executive officer of Promsvyazbank, son of a former prime minister of Russia and former director of the Foreign Intelligence Service (SVR); and
    • Alexander Vedyakin, first deputy chairman of the executive board of Sberbank.

The United States has also targeted Belarus for its support of the invasion of Ukraine by sanctioning two Belarusian state-owned banks, nine defence firms, and seven regime-connected official and elites.[33]

In addition, the Bureau of Industry and Security of the U.S. Commerce Department has issued a final rule, released and effective February 24, implementing a series of broad new export controls targeting Russian defense, aerospace, and maritime industries.[34] The new Rule lists new items not previously subject to controls, including semiconductors, computers, telecommunications, information security equipment, lasers, and sensors, as well foreign items produced outside of the United States using U.S. equipment, software, and blueprints. It also imposes stringent controls on 49 Russian military end users.[35]

On January 28, the U.S. announced new restrictions preventing has just issued new restrictions, prohibiting U.S. persons from engaging in transactions with the Central Bank, National Wealth Fund, and Ministry of Finance of the Russian Federation, with the effect of immobilizing those assets held in the U.S. or by U.S. persons.[36] It is expected that Canada and its allies will shortly follow suit, given joint announcements on February 26, 2022.

United Kingdom

On February 24, 2022, the United Kingdom also announced sanctions targeting Russian financial institutions and individuals:

  • An asset freeze of all Russian banks, including VTB Bank,[37] preventing them from undertaking any business in the UK or with UK nationals;
  • An asset freeze of defence-related companies JSC Research Corporation and Uralvagonzavod, Rostec, Tactical Missiles Corporation, United Aircraft Corporation, United Shipbuilding Corporation;[38]
  • An asset freeze and travel ban for eight named individuals, including:[39]
    • Kirill Shamalov, director of petrochemical company Sibur and Putin’s former son-in-law;
    • Petr Fradkov, described under US sanctions;
    • Denis Bortnikov, a deputy president of VTB Bank and chair of its management board, as well as the son of the director of the Russian Federal Security Service; and
    • Yuri Slyusar, general director of United Aircraft Corporation, a major aircraft manufacturer, and a key figure in the Russian defence sector.

These were supplemented on February 25, 2022 with the addition of Vladimir Putin and Sergei Lavrov, Minister of Defence, to the sanctions list.[40] In addition, the UK will introduce new, as yet unspecified. trade restrictions and stringent export controls targeting electronics, telecoms and aerospace companies. Russia’s national airline Aeroflot will also be banned from UK airspace.[41]

European Union

The European Union has introduced certain measures parallel to the sanctions discussed above, with a first set of measures introduced on February 23, 2022,[42] and a second set on February 25, 2022.[43] Individual restrictive measures will apply to a total of 654 individuals and 52 entities, and include an asset freeze and a prohibition from making funds available to the listed individuals and entities, as well as a travel ban prohibiting these persons from entering or transiting through the EU. Targeted individuals and entities include:[44]

  • The 351 members of the Russian Duma who voted in favour of the recognition of Donestk and Kuhansk as independent entities, as well as the remaining members of the who ratified the government decision of the Treaty of Friendship, Cooperation and Mutual Assistance with those entities;
  • Key individuals including Vladimir Putin, Sergei Lavrov (Minister of Foreign Affairs), Sergei Shoigu (Minister of Defence), Maxim Reshetnikov (Minister of Economic Development and member of the supervisory council of the VTB Bank), and numerous commanders in the Russian Military; and
  • An asset freeze of defence-related companies JSC Research Corporation and Uralvagonzavod, Rostec, Tactical Missiles Corporation, United Aircraft Corporation, United Shipbuilding Corporation, as well as the Internet Research Agency, an internet ‘troll farm’ engaged in online influence operations on behalf of Russian government interests.

In addition, the EU has introduced a sectoral prohibition on financing the Russian Federation, its government and Central Bank, restricting the ability of the Russian state and government to access the EU’s capital and financial markets and services. It has also introduced an export ban covering goods and technologies relating to oil refining, the aviation and space industry, and dual-use goods and technology as well as certain defence and security-sector technology, including semi-conductors and other technologies. The EU has also announced that it will be closing its airspace to Russian aircraft.[45]

Germany has separately taken action in the form of halting the permit approval for the Nord Stream 2 gas pipeline from Russia.[46]

Time will tell whether these measures will deter increasing Russian aggression towards Ukraine

The situation remain very fluid, with new sanctions and export controls being announced on an almost daily basis.

According to Prime Minister Trudeau, Canada is “looking for Russia to stand down, to cease its violations of Ukrainian sovereignty, Ukrainian territorial integrity, to return to negotiation tables”.[47] Only time will tell whether, combined with those of Canada’s international counterparts, these initial rounds of economic sanctions will prove effective in deterring Russia’s ever-growing aggression towards Ukraine. Otherwise, Canada and its global counterparts have warned that more, and harsher, sanctions are to come.

In the interim, companies with business activities in Russia, Ukraine or Belarus should keep a close eye on amendments to sanctions legislation around the globe, as economic sanctions are certain to play an important, and dynamic, role in managing this international crisis. Moreover, as we have previously advised, companies should bear in mind that even where international counterparts are acting in tandem when imposing sanctions, there is no guarantee of identical or even consistent measures. This makes it important to consider sanctions-related compliance on a country-by-country basis and to calibrate compliance programs accordingly.

*****

[1] Global Affairs Canada, “Canadian Sanctions Related to Russia” (updated February 24, 2022): https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/russia-russie.aspx?lang=eng.

[2] Government of Canada, “Canada announces additional measures to support Ukraine” (February 24, 2022): https://pm.gc.ca/en/news/news-releases/2022/02/24/canada-announces-additional-measures-support-ukraine.

[3] The recorded announcement is available on CTV News: see Sarah Turnbull, “PM announces 'first round' of sanctions against Russia, troop deployment to Latvia”, CTV News (February 22, 2022): https://www.ctvnews.ca/politics/pm-announces-first-round-of-sanctions-against-russia-troop-deployment-to-latvia-1.5791222.

[4] Government of Canada, “Canada announces additional measures to support Ukraine” (February 24, 2022): https://pm.gc.ca/en/news/news-releases/2022/02/24/canada-announces-additional-measures-support-ukraine.

[5] The recorded announcement is available on Global News: see Eric Stober, “Canada to place sanctions on Putin for Russian invasion of Ukraine” (February 25, 2022): https://globalnews.ca/news/8646887/canada-vladimir-putin-sanctions-russia-ukraine-invasion/ [February 25, 2022 Announcement].

[6] Global Affairs Canada, “Notice to Exporters and Brokers – Export and Brokering of items listed on the Export Control List and the Brokering Control List to Belarus” (November 9, 2020): https://www.international.gc.ca/trade-commerce/controls-controles/notices-avis/1033.aspx?lang=eng.

[7] Transport Canada, “Government of Canada prohibits Russian aircraft to enter Canadian airspace” (February 27, 2022): https://www.canada.ca/en/transport-canada/news/2022/02/government-of-canada-prohibits-russian-aircraft-to-enter-canadian-airspace.html.

[8] Statistics Canada. Table 12-10-0011-01 International merchandise trade for all countries and by Principal Trading Partners, monthly (x 1,000,000): https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1210001101 and Statistics Canada. Table 36-10-0024-01 Balance of international payments, current account, services by principal trading partners, quarterly (x 1,000,000): https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3610002401.

[9] Statistics Canada. Table 36-10-0008-01 International investment position, Canadian direct investment abroad and foreign direct investment in Canada, by country, annual (x 1,000,000): https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=3610000801.

[10] Library of Parliament, Canadian Trade and Investment Activity: Canada–Russia (September 18, 2017): https://lop.parl.ca/sites/PublicWebsite/default/en_CA/ResearchPublications/TradeAndInvestment/2017593E

[11] Global Affairs Canada, “Canada’s response to the crisis in Ukraine” (Updated February 25, 2022), online: https://www.international.gc.ca/world-monde/issues_development-enjeux_developpement/response_conflict-reponse_conflits/crisis-crises/ukraine.aspx?lang=eng&utm_campaign=gac-amc-ukraine-21-22&utm_source=gacinternationalhome&utm_medium=feat&utm_content=en.

[12] SOR/2014-58.

[13] SOR/2014-60.

[14] SOR/2020-214.

[15] Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-0027 [Amendments to Russia Regulations, Round 1].

[16] Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2022-0029 [Amendments to Russia Regulations, Round 2].

[17] VEB was previously listed in Schedule 2 and has now been moved to Schedule 1. This movement expands the sanctions applicable to this bank, as entities listed on Schedule 2 are only subject to debt and equity financing restrictions.

[18] Amendments to Russia Regulations, Round 1, supra note 15.

[19] Amendments to Russia Regulations, Round 2, supra note 16.

[20] Sberbank was previously listed in Schedule 2 and has now been moved to Schedule 1. This movement expands the sanctions applicable to this bank, as entities listed on Schedule 2 are only subject to debt and equity financing restrictions.

[21] Amendments to Russia Regulations, Round 1, supra note 15.

[22] February 25, 2022 Announcement, supra note 5.

[23] Amendments to Russia Regulations, Round 1, supra note 15.

[24] Amendments to Russia Regulations, Round 1, supra note 15.

[25] Regulations Amending the Special Economic Measures (Ukraine) Regulations, SOR/2022-0028 [Amendments to Ukraine Regulations, Round 1]; Regulations Amending the Special Economic Measures (Ukraine) Regulations, SOR/2022-0030 [Amendments to Ukraine Regulations, Round 2].

[26] Amendments to Ukraine Regulations, Round 1, supra note 25.

[27] Amendments to Ukraine Regulations, Round 2, supra note 25. See also Government of Canada, “Canada announces additional measures to support Ukraine” (February 24, 2022): https://pm.gc.ca/en/news/news-releases/2022/02/24/canada-announces-additional-measures-support-ukraine.

[28] February 25, 2022 Announcement, supra note 5.

[29] DIRECTIVE 2 UNDER EXECUTIVE ORDER 14024: Prohibitions Related to Correspondent or Payable-Through Accounts and Processing of Transactions Involving Certain Foreign Financial Institutions (February 24, 2022): https://home.treasury.gov/system/files/126/correspondent_accounts_directive_2.pdf.

[30] Global Affairs Canada, “Notice to Exporters and Brokers – Export and Brokering of items listed on the Export Control List and the Brokering Control List to Belarus” (November 9, 2020): https://www.international.gc.ca/trade-commerce/controls-controles/notices-avis/1033.aspx?lang=eng.

[31] “U.S. Treasury Imposes Immediate Economic Costs in Response to Actions in the Donetsk and Luhansk Regions”, (February 22, 2022): https://home.treasury.gov/news/press-releases/jy0602.

[32] “U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs”, (February 24, 2022): https://home.treasury.gov/news/press-releases/jy0608.

[33] U.S. Treasury, “U.S. Treasury Targets Belarusian Support for Russian Invasion of Ukraine” (February 24, 2022): https://home.treasury.gov/news/press-releases/jy0607

[34] Bureau of Industry and Security,” Implementation of Sanctions Against Russia Under the Export Administration Regulations” (February 24, 2022): https://public-inspection.federalregister.gov/2022-04300.pdf

[35] “Commerce Implements Sweeping Restrictions on Exports to Russia in Response to Further Invasion of Ukraine”, February 24, 2022: https://www.commerce.gov/news/press-releases/2022/02/commerce-implements-sweeping-restrictions-exports-russia-response.

[36] U.S. Treasury, “Treasury Prohibits Transactions with Central Bank of Russia and Imposes Sanctions on Key Sources of Russia’s Wealth” (February 28, 2022): https://home.treasury.gov/news/press-releases/jy0612.

[37] HM Treasury Notice, Russia Amendment (February 24, 2022): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057300/Notice_Russia_240222_amend.pdf.

[38] HM Treasury Financial Sanctions Notice (February 24, 2022): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057264/Notice_Russia_240222.pdf.

[39] HM Treasury Financial Sanctions Notice (February 24, 2022): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057264/Notice_Russia_240222.pdf.

[40] HM Treasury, Office of Financial Sanctions Implementation, Financial Sanctions Notice (February 25, 2022): https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1057547/Notice_Russia_250222.pdf.

[41] “Foreign Secretary imposes UK’s most punishing sanctions to inflict maximum and lasting pain on Russia”, February 24, 2022: https://www.gov.uk/government/news/foreign-secretary-imposes-uks-most-punishing-sanctions-to-inflict-maximum-and-lasting-pain-on-russia.

[42] EU COUNCIL DECISION (CFSP) 2022/265 of 23 February 2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D0265&qid=1645800879383

[43] Council of the EU “Russia’s military aggression against Ukraine: EU imposes sanctions against President Putin and Foreign Minister Lavrov and adopts wide ranging individual and economic sanctions” (February 25, 2022): https://www.consilium.europa.eu/en/press/press-releases/2022/02/25/russia-s-military-aggression-against-ukraine-eu-imposes-sanctions-against-president-putin-and-foreign-minister-lavrov-and-adopts-wide-ranging-individual-and-economic-sanctions/

[44] EU COUNCIL DECISION (CFSP) 2022/265 of 23 February 2022: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022D0265&qid=1645800879383

[45] Tweet by Ursula von der Leyen, President of the EU Commission (February 27, 2022): https://twitter.com/vonderleyen/status/1497973334847414278?cxt=HHwWjICzqfez78kpAAAA

[46] “Ukraine crisis: Germany halts pipeline as nations sanction Russia”, BBC (February 22, 2022): https://www.bbc.com/news/world-europe-60480734.

[47] Lee Berthiaume, “Canada commits troops, sanctions Russia as Kremlin orders troops into Ukraine”, CityNews (February 22, 2022), online: https://kitchener.citynews.ca/national-news/canada-commits-troops-sanctions-russia-as-kremlin-orders-troops-into-ukraine-5090907.

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