Authors: Kahina Haroune, Lydia Blois, Drew Tyler
The Government of Canada recently imposed sanctions on additional entities and individuals under its existing sanctions on Belarus.
On June 21, 2021, the Government of Canada expanded its existing sanctions regime under the Special Economic Measures Act (“SEMA”) with respect to Belarus. It amended the Special Economic Measures (Belarus) Regulations (“Belarus Regulations”) to impose sanctions against 5 new entities and 17 new individuals. These latest sanctions target key senior officials, lawmakers, ministers from President Lukashenko’s administration, and affiliated commercial entities. Canada’s measures are being taken in coordination with the United States, the United Kingdom and the European Union.
The Belarus Regulations now impose sanctions on 5 entities and 72 individuals in response to “gross and systematic violations of human rights” occurring in Belarus. The sanctions continue to impose an asset freeze, prohibiting persons in Canada, and Canadians outside of Canada, from engaging in any activity related to any property of these entities and/or individuals.
Background on Belarusian Sanctions
On September 29, 2020, the Belarus Regulations were first enacted with sanctions against 11 Belarusian officials following a presidential election marred by widespread irregularities. Canada condemned the numerous human rights violations observed, including violations of the right to free and fair elections, liberty and security of the person, freedom of expression and peaceful assembly.
The Government of Canada imposed further sanctions against an additional 31 Belarusian officials on October 15, 2020, citing continued disregard for human rights, freedom of press and freedom of expression.
On November 6, 2020, the Government of Canada imposed further sanctions in response to the Belarusian Government’s lack of cooperation in finding a negotiated solution with opposition groups and for failing to ensure those responsible for human rights violations were held accountable. The sanctions targeted an additional 13 Belarusian officials.
The latest June 21, 2021 amendments were made in response to the Lukashenko regime’s continued attacks on human rights and fundamental freedoms. They are in response to the May 23, 2021, diversion and forced landing of a commercial Ryanair flight in Minsk, and the politically motivated arrest of journalist Raman Pratasevich.
Canada’s Sanctions Regime
Sanctions are key tools for the international community to support peace and security and enforce international laws and norms. The Government of Canada imposes sanctions through three statutes, the SEMA, the United Nations Act (“UNA”), and the Justice for Victims of Corrupt Foreign Officials Act.
Canada has imposed SEMA sanctions that target 13 countries and UNA sanctions that target 12 countries and various terrorist entities. Canada has imposed sanctions on 70 foreign nationals under the Justice for Victims of Corrupt Foreign Officials Act.
Canadian companies that do business overseas should actively monitor their supply chains for potential sanctions risk. In particular, all Canadian companies with links to a country where Canadian sanctions are in place should have a compliance program that accounts for the level of risk associated with their operations.
If you have any questions or would like to learn more about compliance with sanctions imposed by Canada, please contact the author of this article.
 Special Economic Measures (Belarus) Regulations (SOR/2020-214).