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Eloise Somera

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Eloise Somera is an Articling Student from Baker McKenzie, Toronto office.

On 31 January 2023, Canada announced amendments to the Special Economic Measures (Burma) Regulations in response to the “ongoing repression of the people of Myanmar by the military”. These amendments list an additional six individuals under the Schedule of the Regulations, and include a new prohibition on the export, sale, supply or shipment of aviation fuel (wherever situated globally) destined for Myanmar or any person in Myanmar. These amendments took effect on 27 January 2023.

Throughout 2022, there were substantial legislative developments under Canada’s unilateral sanctions regime. New sanctions regulations were implemented or amended in response to the war in Ukraine and in response to conflicts in Haiti, Iran and Myanmar. The framework and application of Canadian sanctions law also underwent changes, including the introduction of a new asset forfeiture regime. Additionally, for the first time, a Canadian court opined on the issue of “control” under the Special Economic Measures Act.

On 9 January 2023, Canada announced further amendments to the Special Economic Measures (Iran) Regulations in response to those who “systematically violate human rights and spread the Iranian regime’s propaganda and misinformation.” These amendments list an additional two individuals and three entities under Schedule 1 of the Regulations and entered into force on 6 January 2023. Unlike past announcements, the government’s News Release provides particulars describing each newly designated individual and entity.

On 10 January 2023, Canada enacted the Special Economic Measures (Sri Lanka) Regulations in response to former state officials responsible for committing “gross and systemic violations of human rights.” The Regulations entered into force on 6 January 2023 and list four individuals on Schedule 1, including former Presidents Gotabaya Pajapaksa and Mahinda Rajapaksa.

On 5 December 2022, Canada announced amendments to the Special Economic Measures (Haiti) Regulations in response to the “egregious conduct of Haitian elites who provide illicit financial and operational support to armed gangs”. These amendments list an additional three individuals under the Schedule of the Regulations and took effect on 2 December 2022.