The scope of sanctions imposed by Canada and its allies against Russia has never reached such a threshold. These sanctions are based on (i) the almost daily addition of persons and entities subject to prohibitions under the Special Economic Measures Regulations (Russia-Ukraine) and (ii) the cessation of the issuance of any new export permits to Russia of export-controlled goods and technology (except medical equipment and for humanitarian grounds), which represents the cancellation of several hundred million dollars of sales.

Canada prohibits any Canadian from importing or purchasing petroleum products and now applies a minimum tariff of 35% on all imported Russian goods. Aircraft operated by a Russian operator and boats flying the Russian flag or used by a person from Russia are respectively prohibited from flying over Canadian territory and from docking at a Canadian port.

Finally, Canada and its allies have decided to disconnect some Russian banks from the SWIFT messaging system and prevent the Russian Central Bank from deploying its international reserves.

Despite these sanctions, dealing with Russia remains possible but extremely complex and tedious. All parties to a transaction will want to ensure that they do not violate one of the many measures adopted by Canada and its allies in addition to having to manage reputational risk by continuing to deal with this part of the globe.

For information on how to deal with sanctions, please do not hesitate to contact Bernard Colas or one of our other CMKZ lawyers specializing in international trade law.