On March 10, 2023, Deputy Prime Minister Freeland announced that Canada is banning Russian aluminum and steel imports into Canada. Canada has justified this import ban as a way to "further deny Russia the ability to generate the revenues it needs to pay for its war against Ukraine". This announcement comes exactly one year following Canada's import ban on specific petroleum products from Russia, listed in Schedule 5 of the Special Economic Measures (Russia) Regulations (the "Russia Regulations").
This amendment to the Russia Regulations impacts "the importation of all Russian aluminum products, such as unwrought aluminum, aluminum sheets, and finished products including containers and other household items made from aluminum" as well as "all primary Russian steel products, including iron and non-alloy steel, semi-finished, and finished products such as tubes and pipes". The Russia Regulations have been amended to reflect these changes by adding the list of goods affected by the import ban at Schedule 11, the specific prohibitions at section 3.14 (1) and (2), and by modifying section 5, thereby including the steel and aluminum import ban to "assist" prohibitions.
Our team will continue to closely monitor the prohibitions and sanctions measures related to Russia, providing updates to keep clients informed about important developments affecting trade and services. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits, including under the Special Economic Measures (Russia) Permit Authorization Order.
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