Skip to content

Navigating the waters: Compliance with multiple regimes

By Kim Walsh and Olivia Bungay

Compliance with Russian sanctions goes beyond complying with Canada’s Russia Regulations. Canadian individuals and businesses may be unaware of several other sanctions regimes that apply to them.

In conjunction with its sanctions against Russia, the Canadian Government has placed sanctions against Belarus (Special Economic Measures (Belarus) Regulations) and Russian-occupied areas of Ukraine (Special Economic Measures (Ukraine) Regulations). Similar to the Russia Regulations, the Belarus and Ukraine Regulations list several designated persons and prohibit any person or business in Canada, or any Canadian citizen or business outside of Canada to:

  • Deal in property, wherever situated, that is owned, held or controlled by designated persons or a person acting on behalf of a designated person;
  • Enter into or facilitate a transaction related to a prohibited dealing;
  • Provide any financial or related services in respect of a prohibited dealing;
  • Provide any goods or financial services to a designated person.

Together, the Russia, Belarus and Ukraine Regulations currently list over 2100 designated persons. Aside from prohibiting dealings with designated persons, the Russia, Belarus and Ukraine Regulations prohibit the import and export of certain goods and the provision of certain services in relation to the sanctioned areas. Care must be taken to ensure compliance will all of Canada’s sanctions that target Russia’s invasion of Ukraine.

Aside from Canada’s sanctions, Canadian individuals and businesses conducting business internationally may also be subject to international sanctions regimes. Multinational companies will typically need to follow the sanctions regimes of other countries if there is a sufficient nexus in their operations to that jurisdiction. Compliance with Canada’s sanctions may not equate to compliance with other countries’ sanctions since regimes, while somewhat coordinated, are not identical. Individuals and businesses should also take steps to ensure that their business partners are not “designated persons”/subject to an asset freeze under another country’s regime. Anyone conducting international business should take steps to identify international sanctions that apply to them and ensure they are complied with.

See our recent articles: Navigating Canada’s economic sanctions against Russia and Navigating Canada’s sanctions against Russia: New guidance on ownership and control of an entity

This client update is provided for general information only and does not constitute legal advice. If you have any questions about the above, please contact the author.

Click here to subscribe to Stewart McKelvey Thought Leadership.



Search Archive


“Sale” away: The SCC’s more flexible approach to exclusion clauses in contracts for the sale of goods

July 9, 2024

By Jennifer Taylor & Marina Luro A recent Supreme Court of Canada decision has clarified how to interpret exclusion clauses in sale of goods contracts. The Court in Earthco Soil Mixtures Inc. v Pine Valley…

Read More

Recent case re-confirms temporary ailment is not a disability

June 24, 2024

By Mark Tector and Tiegan A. Scott Decision On April 3, 2024, the Alberta Court of King’s Bench (“ABKB”) upheld a decision of the Chief of the Commissions and Tribunals (the “CCT Decision”), which held…

Read More

Compensation for expropriation: Fair, but not more than fair

June 17, 2024

By Erin Best, Stephen Penney, Robert Bradley, Megan Kieley1 and Elizabeth Fleet1 Expropriation is a live issue in Canadian courts. The Supreme Court of Canada’s decision to broaden the test for constructive expropriation in Annapolis…

Read More

Changes affecting federally regulated employers

June 10, 2024

By Killian McParland and Sophie Poulos There have been many changes in recent months affecting employers governed by federal labour and employment laws. In September 2024, Stewart McKelvey will be hosting a webinar to review…

Read More

Impending changes to Nova Scotia’s Workers’ Compensation Act – Gradual onset stress

June 4, 2024

By Mark Tector and Annie Gray What’s changing? Currently, workers’ compensation coverage in Nova Scotia applies to only a narrow subset of psychological injuries. Specifically, in Nova Scotia – as in all Atlantic Provinces –…

Read More

Appeal Courts uphold substantial costs awards for regulators

May 22, 2024

By Sean Kelly & Michiko Gartshore Professional regulators can incur substantial costs through discipline processes. These costs are often associated with investigations, hearings as well as committee member expenses and are an unfortunate by-product of…

Read More

Less than two weeks to go … Canada Supply Chain Transparency Reports are due May 31st

May 21, 2024

By Christine Pound, ICD.D., Twila Reid, ICD.D., Sarah Dever Letson, CIPP/C, Sheila Mecking, Hilary Newman, and Daniel Roth Introduction The first reports under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the…

Read More

Court upheld municipality’s refusal to disclose investigation report

May 1, 2024

By Sheila Mecking and Sarah Dever Letson A recent decision out of the Court of King’s Bench of New Brunswick,[1] upheld the Municipality of Tantramar’s decision to withhold a Workplace Assessment Report under section 20(1)…

Read More

Occupational Health and Safety sentencing decision – Nova Scotia

April 29, 2024

By Sean Kelly & Tiegan Scott Earlier this month, the Provincial Court of Nova Scotia issued its sentencing decision in R v The Brick Warehouse LP, 2024 NSPC 26, imposing a monetary penalty of $143,750 (i.e.,…

Read More

Canada 2024 Federal Budget paves the way for Open Banking

April 22, 2024

By Kevin Landry On April 15, 2024, the Canadian federal budget was released. Connected to the budget was an explanation of the framework for Canada’s proposed implementation of Open Banking (sometimes called consumer-driven banking). This follows…

Read More

Search Archive

Scroll To Top