Pan-Canadian regulatory group urges market participants to weigh impact of recently imposed government measures
The Canadian Securities Administrators (CSA) is urging all market participants to review their obligations under economic sanctions that the government has imposed on Russia in light of its actions against Ukraine.
In a statement, the CSA alerted market participants to the sanctions put in place under amendments to the Special Economic Measures (Russia) Regulations, which impose broad categories of sanctions on named Russian nationals and entities.
“All market participants are encouraged to do their due diligence and consider obtaining expert advice to understand, follow and continually monitor their obligations under the Regulations,” the statement said.
Those who interact with any of the “designated persons” listed in Schedule 1, 2, or 3 of the regulations, or with their assets or property, may be directly affected by the sanctions, according to the statement.
Among other prohibitions specified under the regulations, the CSA said no person in Canada or Canadian outside Canada is allowed to:
- Deal in any property held by or on behalf of a designated person named in Schedule 1;
- Enter into or facilitate any transaction related to such a dealing;
- Provide any financial or other related services in respect of such a dealing.
“While the sanctions apply beyond the scope of Canadian securities law, all market participants are potentially impacted, including issuers, marketplaces, clearing agencies, custodians, all categories of registrants, including crypto asset trading platforms, and pension, investment and mutual funds and their managers,” the CSA said.
The impact may also reach other entities – such as banks and accounting firms – that facilitate financial transactions or provide financial or audit services with respect to relevant transactions or designated persons, the statement added.
“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,” the CSA said, adding that there are requirements for any situation or proposed transaction involving such property to be reported to the commissioner of the RCMP.
Some sectors, such as the financial and energy sectors, will be impacted by certain restrictions.
“It is also important to note that causing, facilitating or assisting in prohibited activities is likewise prohibited,” the CSA said.
