Canada’s Special Economics Measure Act (SEMA) provides the Government of Canada the authority to impose sanctions on foreign jurisdictions and persons. Since February 24, 2022, Canada has frequently amended the SEMA (Russia) Regulations (SOR/2014-58) (and other regulations enacted under SEMA), to list a significant number of individuals and entities as “designated persons”, thereby imposing a broad prohibition against dealing in the property of, providing financial services to, or engaging in financial transactions with these designated persons.
On August 15, 2022, the Royal Canadian Mounted Police published a statement announcing that from February 24 to August 9, 2022, it had frozen an approximate total of $120 million in CAD equivalent of assets in Canada and had blocked $290 million in financial transactions as a result of the sanctions targeting Russia under the SEMA (Russia) Regulations.
We note that every person in Canada and every Canadian outside of Canada has an obligation to report to the Commissioner of the RCMP any property in their possession or control and any transaction that is believed to relate to a designated person.