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ARTICLE · 11 MARCH 2024

Canada Amends Russia Sanctions To Combat Sanctions Evasion

Osler, Hoskin & Harcourt LLP
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On February 21, 2024, Canada expanded the scope of its sanctions imposed in response to Russia's war in Ukraine.

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Matthew Kronby
Matthew Kronby
Jesse Goldman
Jesse Goldman
Alan Kenigsberg
Alan Kenigsberg
Danielle Chu
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On February 21, 2024, Canada expanded the scope of its sanctions imposed in response to Russia's war in Ukraine. The amendments to the Special Economic Measures (Russia) Regulations (the Russia Regulations) are aimed in large part at preventing circumvention of Russia-related sanctions. They were announced in coordination with the United Kingdom and the United States.

This Osler Update provides a high-level overview of the amendments and key takeaways for businesses.

Background context: evasion

Canada has come under considerable scrutiny from allies and non-governmental organizations for gaps in its existing Russia-related sanctions. For example, a U.S. Treasury report [PDF] published in September 2023 named Canada as one of the top ten countries for Russia-related export control evasion. There have been several reports of electronics and military goods, including detonators, being shipped from Canada to Kazakhstan or Kyrgyzstan and then ultimately to Russia, in

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