Canada hits Russian regime, weapons manufacturers with dealings bans, export prohibitions

By Cristin Schmitz

Law360 Canada (February 27, 2023, 12:04 PM EST) -- Piling on sanctions for Russia’s countrywide expansion one year ago of its now-nine-year-old illegal invasion of Ukraine, Prime Minister Justin Trudeau announced Feb. 24 additional asset freezes and export bans — this time against 13 Russian political entities, 50 “defence” contractors and 122 individuals, including members of Russia’s lower house of Parliament who voted for legislation related to the invasion and the Putin regime’s attempted annexation of the Donetsk, Luhansk, Kherson and Zaporizhzhia regions of Ukraine.

Asset freezes/dealings bans under the Special Economic Measures (Russia) Regulations kicked in Feb. 23 against the individuals who also include Russian deputy prime ministers, ministers and others in the Russian military and in the office of Russian President Vladimir Putin, as well as family members of people previously sanctioned by Canada.

Also targeted are seven senior managers at companies involved in Russia’s military industry, including in producing tanks, missiles and weapons systems that Russia is using in Ukraine.

Prime Minister Justin Trudeau

Prime Minister Justin Trudeau

As of Feb. 23, Canada also prohibited the export to Russia of certain chemical elements for use in electronics and banned the import, purchase, or acquisition of Russian arms, ammunition, and other weapons, wherever situated or processed, from Russia or from any person in Russia.

Effective Feb. 23, 13 Russian Federation institutions are sanctioned, including both houses of the Russian parliament; Putin’s political party, United Russia; the Federal Security Bureau (successor to the Soviet KGB); and Russia’s financial intelligence agency, Rosfinmonitoring and its director.

“Ukrainians have stood strong over the last 365 days and counting, and as Russia continues its brutal war against Ukraine, Canada and Canadians will stand by the Ukrainian people for as long as it takes,” Trudeau said in statements from Global Affairs Canada, marking Russia’s Feb. 20, 2014, illegal invasion of the Crimean Peninsula of Ukraine, and Russia's countrywide illegal invasion, which began Feb. 24, 2022.

“We stand in solidarity with the missing and the displaced, and with the families of those who lost their lives,” Trudeau said, reaffirming Canada’s commitment to Ukrainians “and the principles they're fighting for — democracy, justice, and freedom.”

“Every day, Ukrainians continue to show their courage and resilience as they defend themselves and their country from Russia's brutal attacks on people, including its repeated human rights violations, and targeting of Ukraine's critical infrastructure,” the prime minister said.

The federal government said that since Russia illegally invaded and attempted to annex Crimea in 2014, Canada has sanctioned 1,289 individuals, and 349 entities, under the Special Economic Measures (Russia) Regulations.

Ottawa has also announced immigration bans. The Liberal government introduced changes to the Immigration and Refugee Protection Act to make foreign nationals subject to sanctions under the Special Economic Measures Act inadmissible to Canada, i.e. banning sanctioned Russians from entering the country. “These changes will allow the Canada Border Services Agency to deny entry to, and remove, individuals subjected to sanctions, and will allow Immigration, Refugees and Citizenship Canada officials to deny visas,” the federal government said.

In the year since the Putin regime widened its illegal invasion of Ukraine Feb. 24, 2022, Russia has killed more than 8,000 Ukrainian civilians and injured more than 13,000, including more than 1,400 children. There are more than eight million Ukrainian refugees and more than five million Ukrainians who are internally displaced within their country, which had a pre-war population of around 40 million. Russia has destroyed and damaged historic and cultural landmarks, as well as Ukrainian critical infrastructure and other property that a World Bank study last year estimated will cost $350 billion to rebuild.

Following a referral by Canada and other state parties, the International Criminal Court is investigating the situation in Ukraine with respect to war crimes, crimes against humanity and genocide by Russia. There is growing international pressure, including by Canada, the EU, and the U.K., to create as well a special tribunal to prosecute Russia for the international crime of aggression in order to bring the Kremlin leadership to account for the atrocities and devastation the Putin regime is wreaking in Ukraine.

The federal Department of Finance reported in a Feb. 24 press release that since the Russian Elites, Proxies and Oligarchs Task Force (REPO) was created one year ago by Canada and the other members of the G7, the European Commission and Australia, the member countries have:
  • Blocked or frozen more than $58 billion of sanctioned Russians’ assets in financial accounts and economic resources.
  • Ensured that assets of the Russian Central Bank and National Wealth Fund remain immobilized and cannot be used to support Russia’s war effort.
  • Seized or frozen luxury real estate and other luxury assets owned, held, or controlled by sanctioned Russians, “valued in the many billions of dollars.”
  • Seized, frozen, or detained yachts and other vessels owned, held, or controlled by sanctioned Russians, and conducted asset tracing activities to identify, locate, and seize yachts, aircraft, and other property located around the globe.

As well, task force members have convened six multilateral meetings, consistently shared information and taken collective action to restrict sanctioned Russians’ access to the global financial system, making it more difficult for Russia to procure technology necessary to sustain its unjust war in Ukraine, the Department of Finance said.

The government said the task force works collectively to investigate and counter Russian sanctions evasion, including attempts to hide or obfuscate assets, illicit cryptocurrency and money laundering schemes, illicit Russian defence procurement and sanctioned Russians’ use of financial facilitators.

Task force members, including Canada, also worked to update, or expand and implement, legal frameworks that enable the freezing, seizure, forfeiture and/or disposal of assets.

In February, a U.S. court ordered the first forfeiture of assets belonging to a sanctioned Russian — paving the way for the transfer of US$5.4 million in funds as foreign assistance to Ukraine.

Last December, Canada announced the seizure of US$26 million from Granite Capital Holdings Ltd., a company owned by Russian oligarch Roman Abramovich who is sanctioned under the Special Economic Measures (Russia) Regulations. Global Affairs Canada said the federal Crown would apply in court to have the asset forfeited permanently. If forfeit, the proceeds from the seized asset could be used to help reconstruct Ukraine and compensate the victims of Russia’s illegal invasion, the federal government said.

See here for free access to Law360’s coverage of the war in Ukraine.

If you have any information, story ideas or news tips for Law360 Canada, please contact Cristin Schmitz at or call 613-820-2794.