Ukraine Crisis – Canada Extends Sanctions Net

By | April 29, 2014

There are now 41 individuals listed as designated persons plus three Russian banks. This extends the scope of the sanctions that were promulgated in March.

For Canadian businesses, the critical part of the sanctions is the following:

3. It is prohibited for any person in Canada and any Canadian outside Canada to

  • (a) deal in any property, wherever situated, held by or on behalf of a designated person;
  • (b) enter into or facilitate, directly or indirectly, any transaction related to a dealing referred to in paragraph (a);
  • (c) provide any financial or other related service in respect of a dealing referred to in paragraph (a);
  • (d) make any goods, wherever situated, available to a designated person; or
  • (e) provide any financial or related service to or for the benefit of a designated person.

Particularly significant in the prohibition are the important words, “facilitate, directly or indirectly, any transaction . . . “ that relates to property held “by or on behalf of” one of these designated persons.

Care must be taken to be doubly sure that business transactions do not run afoul of the ever-widening sweep of the net.

Just a note to state what is pretty obvious – be extremely cautious in dealing with Russian businesses and banks.