Authors: Lydia Blois, Linden Dales, and Drew Tyler
On March 22, 2021, the Government of Canada imposed sanctions against four Chinese officials and one Chinese entity under the Special Economic Measures (People’s Republic of China) Regulations. Canada has stated that the sanctions are in response to “gross and systematic” human rights violations in the Xinjiang Uyghur Autonomous Region (“XUAR”) of China. Canada’s measures are being taken in coordination with the United States and the United Kingdom, and in solidarity with those of the European Union.
The four individuals listed as subject to the sanctions are:
Xinjiang Production and Construction Corps Public Security Bureau, a state-owned economic and paramilitary organization in the XUAR, is currently the only listed entity subject to the sanctions.
The Special Economic Measures (People’s Republic of China) Regulations impose a dealings prohibition on the above listed individuals and entity and apply to any person in Canada and any Canadian outside Canada. The Regulations include prohibitions on dealing in the funds or assets of the listed persons, providing goods or services to these persons or facilitating or assisting in activities that are prohibited. The individuals listed in the Schedule to the Regulations are also inadmissible to Canada under the Immigration and Refugee Protection Act.
China has already retaliated against the European Union for its sanctions announced on March 22, 2021, imposing its own sanctions against ten European individuals and four entities. Specifically, China’s retaliatory sanctions include sanctions on European lawmakers, and the following institutions: Political and Security Committee of the Council of the European Union, Subcommittee on Human Rights of the European Parliament, the Mercator Institute for China Studies in Germany, and the Alliance of Democracies Foundation in Denmark.
At the time of writing, it is not yet known whether China will impose retaliatory sanctions against Canada.
Canadian companies with dealings that involve individuals or entities in the XUAR region, or that involve the Chinese Government, the Chinese Communist Party or Chinese Government and Communist Party Officials, should ensure that robust compliance measures are in place. International pressure on China relating to abuses in the XUAR region is mounting, and Canada has signaled with this announcement that it will take part in this campaign. Incremental expansion of these sanctions, by Canada and other nations, is possible.
The sanctions came into force on March 22, 2021. If you have any questions or would like to learn more about sanctions risk and compliance, please contact the authors of this article.
 Global Affairs Canada, News Release, “Canada joins international partners in imposing new sanctions in response to human rights violations in Xinjiang” (March 22, 2021), online: https://www.canada.ca/en/global-affairs/news/2021/03/canada-joins-international-partners-in-imposing-new-sanctions-in-response-to-human-rights-violations-in-xinjiang.html Special Economic Measures (People’s Republic of China) Regulations, SOR/2021-49.  Robin Emmott, “EU, China impose tit-for-tat sanctions over Xinjiang abuses”, Reuters (March 22, 2021), online:
 Special Economic Measures (People’s Republic of China) Regulations, SOR/2021-49, s 12.