Canada Has Imposed Economic Sanctions

and Asset Freezes On The Venezuelan

Maduro Regime

Written By: Cyndee Todgham Cherniak

Date: September 22, 2017

On September 22, 2017, Canada has finally followed the United States and has imposed unilateral economic sanctions on the Maduro Regime in Venezuela.  Global Affairs has issued a Press Release entitled "Canada imposes sanctions on Maduro regime in Venezuela".  Canada has imposed unilateral targeted economic sanctions against 4o Venezuelan officials and individuals under the Special Economic Measures Act.  The Special Economic Measures (Venezuela) Regulations (to be released soon) impose asset freezes and dealings prohibitions on the targeted individuals by prohibiting persons in Canada and Canadians outside Canada from dealing in any property of these individuals or providing financial or related services to them.  The specific prohibitions have not been announced today.

Acording to the Global Affairs Backgrounder, the names of the individuals targeted by the Special Economic Measures (Venezuela) Regulations are:

  • Nicolás MADURO MOROS
  • Tibisay LUCENA RAMÍREZ
  • Elías José JAUA MILANO
  • Tareck Zaidan EL AISSAMI MADDAH
  • Tarek Willians SAAB HALABI
  • Néstor Luis REVEROL TORRES
  • Roy Antonio María CHADERTON MATOS
  • María Iris VARELA RANGEL
  • Pedro Miguel CARREÑO ESCOBAR
  • Diosdado CABELLO RONDÓN
  • Susana Virgina BARREIROS RODRÍGUEZ
  • Freddy Alirio BERNAL ROSALES
  • Delcy Eloína RODRÍGUEZ GÓMEZ
  • Tania D'AMELIO CARDIET
  • Aristóbulo ISTURÍZ ALMEIDA
  • Jorge Jésus RODRÍGUEZ GÓMEZ
  • Francisco José AMELIACH ORTA
  • Carlos Alfredo PÉREZ AMPUEDA
  • Sergio José RIVERO MARCANO
  • Jesús Rafael SUÁREZ CHOURIO
  • Carmen Teresa MELÉNDEZ RIVAS
  • Bladimir Humberto LUGO ARMAS
  • Gustavo Enrique GONZÁLEZ LÓPEZ
  • Elvis Eduardo HIDROBO AMOROSO
  • Remigio CEBALLOS ICHASO
  • Antonio José BENAVIDES TORRES
  • Hermann Eduardo ESCARRÁ MALAVÉ
  • Sandra OBLITAS RUZZA
  • Socorro Elizabeth HERNÁNDEZ HERNÁNDEZ
  • Maikel José MORENO PÉREZ
  • Gladys Maria GUTIÉRREZ ALVARADO
  • Juan José MENDOZA JOVER
  • Luis Fernando DAMIANI BUSTILLOS
  • Lourdes Benicia SUÁREZ ANDERSON
  • Carmen Auxiliadora ZULETA DE MERCHÁN
  • Arcadio de Jesús DELGADO ROSALES
  • Calixto Antonio ORTEGA RÍOS
  • Andrés Eloy MÉNDEZ GONZÁLEZ
  • Manuel Enrique GALINDO BALLESTEROS
  • Vladimir PADRINO LÓPEZ

To the extent that Canadian companies do business with these individuals or Venezuelan entities that may be connected with these individuals, they may have to cease doing business with those persons.  Canadian companies and financial institutions should immediately review their customer/clietn databases and search for these names.  Condominum corporations should determine if any unit holders match the list of sanctioned names.  Investment advisors should determine if they have investment portfolios belonging to theese idividuals (before liquidating their Canadian assets and transferring the money to them).

We called for sanctions earleir this summer.  See Michelle Zillio's articles in the Globe and Mail "Opposition, activist call on Liberals to sanction Venezuelan government" and "Ottawa says it lacks law to sanction Venezuelan government officials".   Michelle Zillio wrote:

"According to SEMA, cabinet – through the governor in council – can take economic measures against a state if it believes that "a grave breach of international peace and security has occurred that has resulted or is likely to result in a serious international crisis." Trade lawyer Cyndee Todgham Cherniak, who advises businesses on how to navigate Canada's sanctions regime, wonders why Canada has used SEMA to sanction countries such as Burma, but not Venezuela."

"We impose sanctions against Burma for their human-rights violations and the instability in that country," she said. "It's consistent with Canadian values to impose sanctions against Venezuela. We can't accept this sort of behaviour."

I am happy to see that the Government of Canada agrees with me.

For more information or to arrange an export controls diagnostic, please contact Cyndee Todgham Cherniak at 416-307-4168 or at Cyndee@LexSage.com. If you would like assistance in managing the process, Heather Innes, formerly in-house counsel at a company with export controls processes, would be happy to assist. Please call Heather at 416-350-1234.  More information about Canada's economic sanctions is posted on the LexSage website.

*LexSage Professional Corporation is approved by the Law Society of Upper Canada