Effective June 21, 2021, the Government of Canada imposed new sanctions against 17 individuals and 5 entities under the Special Economic Measures (Belarus) Regulations (the “Regulations”). The sanctions were imposed in response to alleged systemic human rights violations and the May 23, 2021 diversion, by the Belarusian regime, of Ryanair Flight 4978 from its planned course in order to land in Minsk. The imposition of sanctions by the Government of Canada was taken in coordination with the United Kingdom, European Union, and United States.
Listed persons under the Regulations are considered inadmissible to Canada under the Immigration and Refugee Protection Act. In addition, the Regulations effectively impose an asset freeze on listed persons because, subject to prescribed exceptions, it is prohibited for any person in Canada and any Canadian outside of Canada to:
- deal in any property, wherever situated, that is owned, held or controlled by a listed person or by a person acting on behalf of a listed person;
- enter into or facilitate any transaction related to a dealing referred to in point (1) above;
- provide any financial or related services in respect of a dealing referred to in point (1) above;
- make available any goods, wherever situated, to a listed person or to a person acting on behalf of a listed person; and
- provide any financial or related service to or for the benefit of a listed person.
The Regulations further prohibit any person in Canada and any Canadian outside of Canada from knowingly doing anything that causes, facilitates or assists in, or is intended to cause, facilitate or assist in any of the prohibited activities described above. For additional background information, please see the press release (here) from the Government of Canada regarding the imposition of these sanctions.