Canadian sanctions related to Russia: update

On 3 March 2022, the Department of Finance Canada issued the MFN Withdrawal Order (2022-1),² removing Russia and Belarus from entitlement to MFN treatment under the Customs Tariff effective 2 March 2022.³ The issuance of this Order results in the application of the General Tariff for goods imported into Canada that originate from Russia or Belarus. Under the General Tariff, a tariff rate of 35% ad valorem will now be applicable on virtually all imports originating from Russia and Belarus.⁴ The Order is implemented under section 31 of the Customs Tariff and applies for 180 days unless extended by a resolution adopted by both Houses of Parliament.⁵

On 4 March 2022, Canada amended the Special Economic Measures (Russia) Regulations (Regulations) to add 10 executives in the Russian energy sector working for the state-owned or controlled oil entities Rosneft or Gazprom,⁶ as listed in Part 1 of Schedule 1 of the Regulations as amended.⁷

On 6 March 2022, the Regulations were further amended to add 10 current or former senior government officials and their close associates, as well as agents of disinformation, as listed in Part 1 of Schedule 1 of the Regulations as amended.⁸ The 6 March amendment also prohibits any ship that is registered in Russia or used, leased or chartered, in whole or part, by, on behalf of or for the benefit of Russia, a person in Russia or a designated person from docking in Canada or passing through Canadian waters.⁹

On 10 March 2022, the Regulations were amended once more to add 32 defense entities, most of which are owned by the Russian state or have contracts with the Government of Russia.¹⁰ Additionally, the amendment adds five individuals who are current and former senior officials and associates of the Russian regime.¹¹ Furthermore, any person in Canada and any Canadian outside Canada is prohibited from importing specific petroleum products listed in a new Schedule 5 to the Regulations:¹²