March 9, 2022 | Circular No. 11413

Dear Member,

Further to CL 11409, Transport Canada has issued a new marine security notification (click HERE) advising that the ban on Russian ships is now in effect. The specific wording of the ban, which is being implemented under the direction of Global Affairs Canada under an amendment to the Special Economic Measures (Russia) Regulations, is as per below:

  • It is prohibited for any person to dock in Canada or pass through Canada any ship that is registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a designated person, unless such docking or passage is necessary to safeguard human life or to ensure navigational safety.

It is worth noting that Global Affairs Canada (GAC) provides an exemption process for prohibited activities or transactions under certain limited circumstances, subject to obtaining a permit.  Members who are uncertain as to whether a specific activity is allowed under the current sanctions may wish to consider using this process in order to obtain clarity from GAC. For more information on the exemption / permit process, please click HERE.

We continue to be in regular contact with Transport Canada on the ban’s practical impacts as relates to marine operations, navigational safety and seafarer mobility.  As previously noted, there are no new prohibitions on the movement of seafarers within Canada (or on their ability to enter or leave the country), and we do not expect to see this change going forward.  Indeed, TC’s new security notification explictly states that Canada will continue to enforce all of its obligations related to the protection of  seafarer safety, health and wellbeing.

We will continue to update members on the above as new information becomes available.  In the meantime, a comprehensive overview of all the sanctions the government has implemented in response to the Russia / Ukraine conflict can be found at this LINK.


Karen Kancens
Vice President