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ARTICLE · 13 MARCH 2014

Canadian Sanctions Target Former Ukrainian Government Officials

The Office of the Superintendent of Financial Institutions has issued a notice dated March 5, 2014.

CanadaGovernment, Public Sector

The Office of the Superintendent of Financial Institutions (OSFI) has issued a notice dated March 5, 2014, directing banks, trust companies, insurers and other federally regulated financial institutions (FRFIs) to immediately freeze assets of the former Ukranian president, Viktor Yanukovych, and his close associates and to refrain from having any dealings with these individuals.

Although FRFIs bear the highest compliance burden, these regulations will apply to all persons within Canada, as well to Canadians located outside the country.

In imposing these targeted sanctions, Canada is acting in concert with the EU and the United States. The EU imposed measures on March 5 similar to those implemented by Canada. The Decision of the Council of the European Union provides for the freezing of funds and assets of the same individuals targeted by Canada. In the case of the United States, on March 6, 2014, President Obama signed an Executive Order permitting the blocking of

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