The Canadian Securities Administrators (CSA) is encouraging market participants to get expert advice on how to ensure they follow their obligations under special economic measures that have been issued in light of Russia’s attacks on Ukraine.
The CSA said the Special Economic Measures (Russia) Regulations impose a broad category of sanctions on Russian nationals and their entities and potentially affect a wide array of market participants.
These include issuers, marketplaces, clearing agencies, custodians, all categories of registrants, including crypto asset trading platforms, and pension, investment and mutual funds and their managers. Other entities like banks and accounting firms that help with transactions, or provide financial or audit services in relation to relevant transactions or designated persons, could also be impacted, said the CSA.
The Regulations impose a number of restrictions in certain areas. For example, it is prohibited for any person in Canada and any Canadian outside Canada to:
- Deal in any property, wherever it may be, that is held by or on behalf of a designated person whose name is listed in the Regulations measure
- Enter into any transaction related to such a dealing
- Provide any financial or other related services in respect of such a dealing
- Make any goods, wherever situated, available to a designated person listed in the measures, and
- Provide any financial or related service to a designated person listed.
In addition, certain entities must determine on a continuing basis whether they are in possession or control of property owned or controlled by, or on behalf of, a designated person. There are also requirements to report any such situation, or any proposed transaction involving this kind of property to the RCMP.