Canada has recently imposed further sanctions against Russia under the Special Economic Measures (Russia) Regulations[1] (the “Regulations”) in response to Russia’s invasion of Ukraine. These sanctions are imposed in harmony with Canada’s partners and allies.[2]

Most recently, Canada announced that it was banning the importation of Russian aluminum and steel products that originate from Russia.[3] Therefore, any person in Canada and any Canadian outside of Canada is prohibited from importing, purchasing, or acquiring Russian aluminum and steel products.[4] Specifically, Schedule 11 bans the importation of all Russian aluminum products, such as unwrought aluminum, aluminum sheets, and finished products.[5] Furthermore, it also bans the importation of all primary Russian steel products, which includes iron and non-alloy steel, and semi-finished and finished products.[6]

The Regulations were also amended to prohibit the importation of Russian arms and related materials.[7] Therefore, any person in Canada and any Canadian outside of Canada is prohibited from importing, purchasing, or acquiring any type of Russian weapon, ammunition, military vehicle, or military or paramilitary equipment, or a spare part for any of these goods.[8] In line with these amendments, the Regulations were amended to add hundreds of new individuals and entities under Schedule 1, which are referred to as “designated persons”.[9] The Regulations explicitly prohibit “engaging” with these designated persons.

The recent individuals added to Schedule 1 are senior managers in Russia’s leading defence companies, senior officials in the Russian government, a Russian oligarch, and family members of sanctioned individuals.[10] The recent entities added to Schedule 1 include decision-making and implementing institutions, and private and state-owned-enterprises in Russia’s defence industry.[11] Earlier this year, other individuals and entities were also added to Schedule 1 because they were involved in Russia’s disinformation and propaganda actions.[12]

Persons in Canada or Canadians outside of Canada who are engaged in business transactions or who plan to do so should seek legal advice in order to assess the full impact of these Regulations. Please contact any member of our Global Trade and Customs Group for assistance.

[1] SOR/2014-58.

[2] Department of Finance Canada, News Release, “Canada bans Russian aluminum and steel imports” (10 March 2023), online: Government of Canada .

[3] Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2023-46 (entered into force on March 10, 2023), s 3.14.

[4] Ibid; supra note 2.

[5] Supra note 2; supra note 3 at Schedule 11.

[6] Supra note 2; supra note 3 at Schedule 11.

[7] Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2023-032 (entered into force on February 23, 2023), s 3.13.

[8] Ibid.

[9] Ibid at Schedule 1; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2023-033 (entered into force on February 23, 2023), Schedule 1.

[10] “Canadian Sanctions Related to Russia” (10 March 2023), online: Government of Canada .

[11] Ibid.

[12] Ibid; Regulations Amending the Special Economic Measures (Russia) Regulations, SOR/2023-014 (entered into force on February 2, 2023), Schedule 1.