February 28, 2022 | Circular No. 11406

Dear Member,

Canada has imposed new sanctions in response to Russia’s invasion of Ukraine, which update the existing Special Economic Measures (Russia) Regulations (first published in 2014), and include an expanded list of designated persons and entities with whom persons in Canada (and Canadians outside Canada) are prohibited from engaging.  Specific activities that are prohibited under section 3 of the Regulations include:

  • Dealing in any property held by or on behalf of a designated entity;
  • Entering into or facilitating, directly or indirectly, any transaction related to a property held by or on behalf of a designated entity;
  • Making any goods, wherever situated, available to a designated entity;
  • Providing any financial or related service to or for the benefit of a designated entity.

The updated list of entities to which these prohibitions apply (as per the sanctions introduced last week) can found at the links below:

We are currently seeking guidance from Global Affairs Canada, Transport Canada and CBSA on the potential impacts of these sanctions on maritime commerce in Canadian waters, and will revert with additional information as available.

We are also seeking information from Transport Canada on the potential impacts of the Russia / Ukraine situation on crew change operations in Canada.  Although all current procedures and requirements remain unchanged for the time being, we will let members know should any adustments be expected.


Karen Kancens
Vice President