The Government of Canada recently announced that it has imposed an asset freeze on certain designated persons related to Ukraine and Russia.

Specifically, the sanctions, enacted pursuant to the Special Economic Measures Act, prohibit Canadians and any person in Canada from, among other things (i) dealing in any property held by or on behalf of a designated person; (ii) providing any financial or other related service in respect of the property of a designated person; and (iii) providing any financial or related service to or for the benefit of a designated person. It is further prohibited for any person in Canada or Canadian outside Canada to do anything that causes, assists or promotes anything that is prohibited under the regulations.

The sanctions also require that various financial entities, including securities dealers and advisers determine on a continuous basis whether they are in possession or control of property owned or controlled by or on behalf of a designated person. Relevant disclosures must be made to the RCMP.

The sanctions add to the regulations enacted last month under the Freezing Assets of Corrupt Foreign Officials Act.

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