New additions to Canada’s Russia sanctions list have modest Canadian assets, data suggests

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Though the federal government is adding to its sanctions list, new data from the RCMP suggests — and experts say — that recent Russian additions to that list likely have modest assets and financial business in Canada.

Canada has sanctioned 1,066 Russians and 264 Russian entities since Russia first invaded Ukraine in 2014. Most of those sanctions were introduced in the months after Russia scaled up its invasion in February 2022.

In an update earlier this week, RCMP reported that a cumulative total of $290,582,385 Cdn in financial transactions has been blocked since February 24, 2022 under the Special Economic Measures Act (SEMA) for sanctioned Russian individuals and entities. A cumulative total of $121,945,874 Cdn in assets has been frozen under the same sanctions since February 24, 2022.

The Privacy Act prevents the RCMP from revealing the nature of the sanctioned assets or identifying where they came from.

“The numbers are reported to us by various financial institutions. As they identify potential transactions that relate to SEMA, it is their responsibility to promptly report the amounts,” an RCMP spokesperson said in a media statement.

“However, as they conduct their internal due diligence and in-depth analysis of the operations, they may correct the numbers to provide a more accurate amount.”

Canada’s sanctions numbers stagnated in the latter half of 2022, even though Ottawa has added 252 individuals and 86 entities to its sanctions list since June.

The sanctions prohibit any Canadian or person in Canada from having a wide range of business dealings with the sanctioned individuals and entities. Individuals sanctioned are also inadmissible to Canada.

Though the minister of foreign affairs is responsible for the administration and enforcement of SEMA, the RCMP is responsible for collecting information on sanctioned assets.

Global Affairs Canada referred CBC’s questions on the sanctions numbers to the RCMP. The office of Foreign Affairs Minister Mélanie Joly did not respond to CBC’s inquiries.

Andrea Charron, director of the University of Manitoba’s Centre for Defence and Security Studies, said the sanctions numbers may not be increasing because newly sanctioned Russians don’t do much business in Canada or with Canadians.

“So even though we have many more names — we’re approaching over 2,000 names — it could be that these individuals actually don’t have any assets or are not located anywhere in Canada,” Charron said.

Jessica Davis, president of the intelligence analysis firm Insight Threat Intelligence, said the Russians Canada sanctioned earlier the year likely had more assets and more financial ties to Canada compared to those sanctioned recently.

Sanctions enforcement ‘a tough sell’

“So it’s not surprising that, as we sort of start to really go down that list of politically exposed people, and people who are really closely connected to the Kremlin, that we’re not really seeing very much in terms of additional effects,” Davis said.

Davis said Canada also could do a better job of enforcing its sanctions and stopping sanctions violations — something she attributes in part to political neglect.

“Sanctions enforcement has been a tough sell politically,” she said. “It’s very difficult to go to the polls on this kind of technical issue.”

A lack of qualified investigators and technical expertise on sanctions and sanctions evasion among banks, businesses and law enforcement is also part of the problem, Charron said.

“If you’re already lacking personnel, and it’s a skilled area to be able to investigate and then see if sanctions have been evaded, does [sanctions enforcement] simply fall to the bottom of the list because we’re already asking the police to do a lot with not enough?” Charron said. 

Davis said applying sanctions to Russians and Russian entities with little or no financial ties to Canada can still be worthwhile.

She said Russia likely is looking to exploit countries with fewer sanctions and weaker sanctions enforcement, but new sanctions can help to prevent that.

“So for Canada, it’s really important that we continue to keep pace with our international allies, both to be seen to be doing the same kind of work … but also to be preventing Canada from being seen as a weak jurisdiction or being exploited as a weak jurisdiction on sanctions,” she said.

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