Canadian Sanctions Update: Russia, Belarus, Iran and Haiti Face New Restrictions – JD Supra

Stikeman Elliott LLP
In this post we describe the economic sanctions imposed by Canada since our October 5, 2022 update. While the latest sanctions on Russia, Belarus and Iran are largely incremental extensions of existing measures, a new sanctions regime has been imposed in response to the anarchic violence in Haiti. Greater enforcement against sanctions violators by the Canadian government is anticipated.
Domestic human rights violations and the provision of drones used by Russia in Ukraine prompted the Canadian government to amend the Special Economic Measures (Iran) Regulations to impose a number of new sanctions:
In short, most of the designations relate to the Iranian state’s domestic activities but have recently been expanded to encompass sanctions related to Iran’s supply of drones to Russia that have been used against Ukraine. This is in part related to a rapidly changing global security environment in which Iran is apparently allying itself with Russia at least insofar as Russia’s war in Ukraine is concerned.
In response to the ongoing war in Ukraine and also to the repression of domestic political dissent, several further rounds of sanctions have been imposed on Russia by way of amendments to the Special Economic Measures (Russia) Regulations:
As the war in Ukraine continues, it seems likely that there will be further listings of Russian persons.
On November 17, 2022, Canada amended the Special Economic Measures (Belarus) Regulations to add 22 Belarusian officials including those determined to be complicit in stationing and transporting Russian military personnel and equipment involved in the invasion of Ukraine and the attempted annexation of Ukrainian territory as well as 16 Belarusian companies involved in military manufacturing, technology, engineering, banking and railway transportation. Canada stated that it anticipated that these measures would exert further pressure on the Belarusian leadership and called for President Lukashenko to cease being an instrument of the Russian regime.
Canada implemented a sanctions program in respect of Haiti in response to the ongoing Haitian humanitarian crisis related to armed gangs using the termination of a fuel subsidy to escalate civil unrest and atrocities perpetuated against Haitians, particularly women and girls, on a daily basis.
The Haitian sanctions imposed by Canada highlight a trend of imposing sanctions on the basis of serious human rights violations. Stay tuned for such sanctions in relation to other jurisdictions as Canada is likely to continue to be called on to not overlook allegations of serious human rights violations in other countries.
Another month, further rounds of Canadian economic sanctions. Given the deteriorating state of international relations, widespread human rights violations and Canada’s ongoing albeit slow motion pivot towards greater attention to national security issues and human rights concerns, this pattern seems likely to continue.
In addition, there was recently another indicator of the likelihood of increased enforcement of Canadian sanctions, the violation of which is a criminal offence. Press reports on November 21, 2022 stated that the U.S. government is quietly pressing its allies to tighten up sanctions enforcement in regard to sanctions on Russia.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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