In this post, we describe the economic sanctions imposed by Canada since our March 28, 2023 update, including additional designations of Russian, Belarusian, Iranian and Haitian persons under existing sanctions regimes and a new sanctions regime for Moldova which resulted in the listing of eight persons. In addition, some previously sanctioned individuals from Zimbabwe were delisted. We continue to expect more sanctions and increased levels of sanctions enforcement.

Additional Designations

Russia

On April 5, 2023, the Government of Canada amended the Special Economic Measures (Russia) Regulations to add 14 individuals (largely senior management at Russian companies that provide military services to Russia) and 34 entities (largely military technology and logistics companies).

On May 18, 2023, Canada further amended the Special Economic Measures (Russia) Regulations to add 17 individuals and 18 entities on the stated basis that they are linked to Russian companies that provide military technology and know-how to Russia’s armed forces, family members of listed persons, and members of the Kremlin elite. Canada also designated 30 individuals and 8 entities for alleged involvement in human rights violations, including the reported transfer and custody of Ukrainian children in Russia.

Belarus

On April 5, 2023, Canada further amended the Special Economic Measures (Belarus) Regulations to list 9 entities that are Russian and Belarussian-owned banks in Belarus.

Iran

On March 23, 2023, the Government of Canada stated that it had amended the Special Economic Measures (Iran) Regulations to designate 8 Iranian individuals and 2 entities “in relation to Iran’s gross and systematic violations of human rights and ongoing grave breach of international peace and security.”

On April 28, 2023, Canada amended the Special Economic Measures (Iran) Regulations to designate nine individuals and one entity “in relation to Iran’s gross and systematic violations of human rights and ongoing grave breach of international peace and security.”

Haiti

On March 23, 2023, the Government of Canada amended the Special Economic Measures (Haiti) Regulations to designate two individuals who have, in Canada’s view, “engaged in significant acts of corruption”. The government also said that “current regulations target members of the economic and political elite who have engaged in activities such as orchestrating attacks as well as providing support, particularly in the form of weapons to gangs”.

New Sanctions Program

Moldova

On May 30, 2023, the Government of Canada enacted a new sanctions program in respect of Moldova and designated 7 individuals on the stated basis that “[t]hey are Moldovan oligarchs, business people, parliamentarians and politicians connected to Russia” and one entity on the stated basis that it is “a political party closely connected to one of the individuals who is sanctioned”.

De-listings

Zimbabwe

On March 23, 2023, Canada amended the Special Economic Measures (Zimbabwe) Regulations to de-list 100 individuals who were either deceased, were deemed to no longer be involved in human rights violations and political violence, or are widowed, divorced or separated from listed individuals.

Looking Ahead: More Sanctions, More Enforcement

It is obvious that economic sanctions have become a favoured policy tool of the Canadian government. Stay tuned for more developments.