Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2025-33
Canada Gazette, Part II, Volume 159, Number 6
Registration
SOR/2025-33 February 21, 2025
SPECIAL ECONOMIC MEASURES ACT
P.C. 2025-155 February 21, 2025
Whereas the Governor in Council is of the opinion that the actions of the Russian Federation constitute a grave breach of international peace and security that has resulted in a serious international crisis;
Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Special Economic Measures (Russia) Regulations under paragraph 4(1)(a)footnote a and subsections 4(1.1)footnote b, (2)footnote c and (3) of the Special Economic Measures Act footnote d.
Regulations Amending the Special Economic Measures (Russia) Regulations
Amendments
1 Section 1 of the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in alphabetical order:
- IMO number
- means the unique seven-digit ship identification number required by regulation XI-1/3 of the International Convention for the Safety of Life at Sea, 1974. (numéro OMI)
2 The Regulations are amended by adding the following after section 2:
Schedule 1.1
2.01 A ship whose IMO number is listed in Schedule 1.1 is a ship in respect of which the Governor in Council, on the recommendation of the Minister, is satisfied that there are reasonable grounds to believe is transporting or has transported property or goods on behalf of or for the benefit of Russia or a person in Russia.
3 Section 3.04 of the Regulations is replaced by the following:
Ships
3.04 It is prohibited for any person to dock any of the following ships in Canada or to pass any of the following ships through Canada, unless that docking or passage is necessary to safeguard human life or to ensure navigational safety:
- (a) a ship that is registered in Russia;
- (b) a ship whose IMO number is listed in Schedule 1.1; and
- (c) any other ship that is used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a person listed in Schedule 1, 2 or 3.
4 The marginal note to section 3.05 of the Regulations is replaced by “Petroleum oils and gases”.
5 (1) Subsection 8(1) of the Regulations is replaced by the following:
Application to no longer be listed
8 (1) A person may apply in writing to the Minister
- (a) to have their name removed from Schedule 1, 2 or 3; or
- (b) to have a ship that they own, operate or manage removed from Schedule 1.1.
(2) Subsection 8(2) of the English version of the Regulations is replaced by the following:
Recommendation
(2) On receipt of the application, the Minister must decide whether there are reasonable grounds to recommend the removal to the Governor in Council.
6 Part 1 of Schedule 1 to the Regulations is amended by adding the following in numerical order:
- 1433 Aleksandra MELNICHENKO (born on April 21, 1977) (also known as Sandra Nikolic)
- 1434 Denis Valentinovich KAMYSHEV (born on November 5, 1975)
- 1435 Hubert SEIPEL (born 1950)
- 1436 Vladimir Vladimirovich POZNER (born on April 1, 1934)
- 1437 Yelena Valeryevna VYALBE (born on April 20, 1968) (also known as Elena Valerievna Vyalbe, Yelena Välbe, Yelena Valeryevna Trubitsyna)
- 1438 Ilya Andreyevich GAMBASHIDZE (born on May 7, 1977)
- 1439 Vladimir Grigoryevich TABAK (born on December 2, 1986)
- 1440 Nikolai Aleksandrovich TUPIKIN (born on June 6, 1977) (also known as Nikolay Tupikin)
- 1441 Sofia ZAKHAROVA
- 1442 Aleksey Sergeyevich GORESLAVSKY (born on July 13, 1977)
- 1443 Timofey Vladimirovitch VASSILIEV (also known as Timofei Vladimirovich Vasilyev)
- 1444 Aleksandr Gennad’yevich STARUNSKY (born on June 12, 1970) (also known as Aleksandr Gennadyevich Starunskiy)
- 1445 Denis Valerievich TYURIN (born on April 1, 1976)
- 1446 Elizaveta Yuryevna BRODSKAYA (born on April 22, 1979) (also known as Elizaveta Yuryevna Brodskaia)
- 1447 Andrey Vladimirovich KIYASHKO (born on December 11, 1988)
- 1448 Konstantin KALASHNIKOV (also known as Konstiantyn Kalashnikov)
- 1449 Elena Mikhaylovna AFANASYEVA (born on June 22, 1997) (also known as Yelena Mikhailovna Afanasieva, Helena Shudra or Victoria Pesti)
- 1450 Aleksey Alekseyevich GARASHCHENKO (born on February 3, 1986)
- 1451 Anastasia Igorevna YERMOSHKINA (born on July 27, 1992)
- 1452 Aleksandr Vitalyevich NEZHENTSEV (born on November 10, 1992)
- 1453 Konstantin Albertovich FEDORENKO (born on December 29, 1976)
- 1454 Oleg Yuryevich NESTEROV (born on August 13, 1980)
- 1455 Yevgeniy Rodionovich KIM
- 1456 Oleg Nikolaevich KOZHEMYAKO (born on March 17, 1962)
- 1457 Ilya Vasilevich REBROV (born on October 10, 1976) (also known as Ilia Vasilyevich or Vasilievich)
- 1458 Igor Alekseevich ALTUSHKIN (born on September 10, 1970)
- 1459 Dzhamaldin Emirmagomedovich PASHAYEV
- 1460 Mark Sergeevich BUZUK (born on July 9, 1968)
- 1461 Vasily Vasilyevich ANISIMOV (born on September 18, 1951) (also known as Vasili Vasilievich Anisimov)
- 1462 Anna Evgenievna TSIVILEVA (born on May 9, 1972) (also known as Anna Evgenievna Tsivilyova)
- 1463 Sergey Yevgenyevich TSIVILEV (born on September 21, 1961) (also known as Sergei Evgenievich Tsivilyov)
- 1464 Dmitry Lvovich LOGINOV
7 Part 2 of Schedule 1 to the Regulations is amended by adding the following in numerical order:
- 653 Russian Copper Company (also known as RCC)
- 654 Iran Air (also known as Iran Air Cargo, HOMA and Hayapeymayi Melli Iran)
- 655 Fast Bunkering Holding, Ltd.
- 656 Belmagistralavtotrans Speditions GmbH (also known as BMA Spedition GMBH)
- 657 Global Ports Managing Company LLC
- 658 Vostochnaya Stevedoring Company LLC (also known as VSC, VSK)
- 659 Akhmat Kadyrov Foundation (also known as AKF)
- 660 The Federal State Budget Educational Institution Artek International Children’s Center (also known as Artek)
- 661 Aerospace Forces of the Ministry of Defence of the Russian Federation (also known as Russian Air, Space Forces and VKS)
- 662 The 924th State Centre for Unmanned Aviation
- 663 Command of the Military Transport Aviation
- 664 Nuclear, Chemical and Biological Defence Troops of the Ministry of Defence of the Russian Federation (also known as Radiological Chemical and Biological Defence troops)
- 665 Sea River Service LLC
- 666 Commercial Seaport Olya
- 667 IRGC Research and Self Sufficiency Jihad Organization (IRGC RSSJO)
- 668 Vpower Finance Security Hong Kong Limited
- 669 Taube Precious HK Limited
- 670 Holden International Trading Ltd.
- 671 DMT Trading LLC
- 672 DMT Electronics (also known as DMT Elektroniks)
- 673 Smart Kit Technology Limited (also known as Smart Kit)
- 674 Siliborn Technology Limited
- 675 YLH Electronics HK Co Limited
- 676 Hongkong Chip Line International Co.
- 677 Hengye Tech Limited.
- 678 LL Electronic Limited
- 679 Allchips Limited
- 680 Fepood Electronics HK Co Limited
- 681 Xin Quan Electronics Co Limited
- 682 Jinhua Hairun Power Technology Co Ltd
- 683 Ace Era Co Limited
- 684 Shenzhen Royo Technology Co Limited
- 685 Qingdao Hehuixin International Trade Co Ltd
- 686 HK Cinty Co Limited
- 687 Foshan Golden Age Motor Technology Co., Ltd.
- 688 Asia Material Solutions Company Limited
- 689 Poly Technologies, Inc. (also known as PTI)
- 690 The Social Design Agency
- 691 Structura National Technologies LLC (also known as Company Group Structura LLC, GK Struktura)
- 692 ANO Dialog (also known as AUTONOMOUS NON-PROFIT ORGANIZATION DIALOG)
- 693 Internet Development Institute (IRI) (also known as l’Institute for Internet Development)
- 694 Azia Shipping Holding Ltd.
- 695 Ibex Shipping Inc.
- 696 Toplivo Bunkering Company (also known as TBK JSC)
8 The Regulations are amended by adding, after Schedule 1, the Schedule 1.1 set out in the schedule to these Regulations.
9 (1) Items 38.1 to 38.4, 39.1 and 39.2 of Schedule 7 to the Regulations are repealed.
| Item | Column 1 Goods |
Column 2 Harmonized Commodity Description and Coding |
|---|---|---|
| 38 | Ball or roller bearings | 8482 |
Application Before Publication
10 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.
Coming into Force
11 These Regulations come into force on the day on which they are registered.
SCHEDULE
(Section 8)
SCHEDULE 1.1
(Section 2.01 and paragraphs 3.04(b) and 8(1)(b))
| Item | IMO number | Vessel name | Type | Build date |
|---|---|---|---|---|
| 1 | 7612448 | Balitiyskiy III | General Cargo / Multi Purpose | 1980 |
| 2 | 8846814 | Musa Jalil | General Cargo / Multi Purpose | 1989 |
| 3 | 8858087 | Skif V | General Cargo / Multi Purpose | 1984 |
| 4 | 8889385 | Omskiy 103 | General Cargo / Multi Purpose | 1978 |
| 5 | 8943210 | Begey | General Cargo / Multi Purpose | 1985 |
| 6 | 9144782 | Bodhi | Oil Tanker | 1997 |
| 7 | 9161003 | Lady R | Ro-Ro Cargo | 2004 |
| 8 | 9179842 | Angara | Ro-Ro Cargo | 1998 |
| 9 | 9216298 | East Energy | LNG Tanker | 2002 |
| 10 | 9232888 | Ksena | Oil Tanker | 2003 |
| 11 | 9243148 | Everest Energy | LNG Tanker | 2003 |
| 12 | 9248801 | Mu Dan | Oil Tanker | 2003 |
| 13 | 9249130 | Peace | Oil Tanker | 2004 |
| 14 | 9250531 | Python | Oil Tanker | 2004 |
| 15 | 9250543 | Neomi | Oil Tanker | 2004 |
| 16 | 9250892 | Mikati | Oil Tanker | 2003 |
| 17 | 9253325 | Nurkez | Oil Tanker | 2004 |
| 18 | 9255660 | Pontus I | Oil Tanker | 2004 |
| 19 | 9256602 | Pioneer | LNG Tanker | 2005 |
| 20 | 9257022 | Laconia | Oil Tanker | 2003 |
| 21 | 9258868 | Asher | Oil Tanker | 2003 |
| 22 | 9259185 | Daksha | Oil Tanker | 2005 |
| 23 | 9271951 | Facca | Chemical/Products Tanker | 2005 |
| 24 | 9274434 | Sindhu | Oil Tanker | 2003 |
| 25 | 9281011 | Moti | Oil Tanker | 2004 |
| 26 | 9282479 | Minerva M | Oil Tanker | 2005 |
| 27 | 9285835 | Sea Fidelity | Oil Tanker | 2005 |
| 28 | 9285859 | Eastern Pearl | Oil Tanker | 2006 |
| 29 | 9286657 | Lokosao | Oil Tanker | 2005 |
| 30 | 9288693 | Andaman Skies | Oil Tanker | 2004 |
| 31 | 9288708 | Stratos Aurora | Oil Tanker | 2005 |
| 32 | 9288710 | Kudos Stars | Oil Tanker | 2005 |
| 33 | 9288722 | Azure Celeste | Oil Tanker | 2005 |
| 34 | 9288746 | Udaya | Oil Tanker | 2005 |
| 35 | 9288899 | Lorena Grand | Oil Tanker | 2005 |
| 36 | 9289520 | N Cerna | Chemical/Products Tanker | 2005 |
| 37 | 9289752 | Savitri | Products Tanker | 2005 |
| 38 | 9290309 | Hulda | Oil Tanker | 2004 |
| 39 | 9292204 | Andromeda | Oil Tanker | 2005 |
| 40 | 9292503 | Bull | Oil Tanker | 2005 |
| 41 | 9292981 | Sagar Violet | Oil Tanker | 2004 |
| 42 | 9293155 | Junia | Oil Tanker | 2005 |
| 43 | 9296391 | Peta Lumina | Oil Tanker | 2006 |
| 44 | 9296822 | Sagitta | Oil Tanker | 2005 |
| 45 | 9297371 | Suleyman I | Oil Tanker | 2006 |
| 46 | 9299666 | Dashan | Oil Tanker | 2005 |
| 47 | 9299692 | Callisto | Oil Tanker | 2005 |
| 48 | 9299721 | Leona | Oil Tanker | 2006 |
| 49 | 9299733 | Nagarjuna | Oil Tanker | 2006 |
| 50 | 9299898 | Turbo Voyager | Oil Tanker | 2005 |
| 51 | 9305568 | Breeze | Oil Tanker | 2005 |
| 52 | 9306794 | Constellation | Oil Tanker | 2006 |
| 53 | 9311622 | Vanguard | Oil Tanker | 2006 |
| 54 | 9312884 | Kemerovo | Oil Tanker | 2007 |
| 55 | 9312896 | Krasnoyarsk | Oil Tanker | 2007 |
| 56 | 9314167 | Agnes | Oil Tanker | 2007 |
| 57 | 9316127 | Vega | Oil Tanker | 2007 |
| 58 | 9317949 | Xiwang | Oil Tanker | 2007 |
| 59 | 9318539 | Swiftsea Rider | Oil Tanker | 2007 |
| 60 | 9319882 | Aryabhata | Oil Tanker | 2007 |
| 61 | 9321689 | Ocean Faye | Oil Tanker | 2007 |
| 62 | 9321691 | Sai Baba | Oil Tanker | 2006 |
| 63 | 9321847 | Emily S | Oil Tanker | 2006 |
| 64 | 9323986 | Garasan | Oil Tanker | 2007 |
| 65 | 9324277 | Nova Energy | LNG Tanker | 2007 |
| 66 | 9331141 | Kelly Grace | Oil Tanker | 2006 |
| 67 | 9331153 | Delvina | Oil Tanker | 2007 |
| 68 | 9332781 | Lang Ya | Oil Tanker | 2006 |
| 69 | 9332810 | Kiwala | Oil Tanker | 2007 |
| 70 | 9333424 | Phoenix | Oil Products Tanker | 2007 |
| 71 | 9333436 | Success | Oil Products Tanker | 2007 |
| 72 | 9339325 | Liberty | Oil Tanker | 2007 |
| 73 | 9339337 | Legacy | Oil Tanker | 2008 |
| 74 | 9341079 | Capella | Oil Tanker | 2006 |
| 75 | 9341081 | Cassiopeia | Oil Tanker | 2006 |
| 76 | 9341093 | Kolomna | Oil Tanker | 2006 |
| 77 | 9353096 | Madhav | Chemical/Products Tanker | 2008 |
| 78 | 9354313 | Zaliv Amurskiy | Oil Tanker | 2008 |
| 79 | 9394935 | Ozanno | Oil Tanker | 2008 |
| 80 | 9402471 | Apar | Oil Tanker | 2009 |
| 81 | 9408205 | Fast Kathy | Oil Tanker | 2010 |
| 82 | 9410870 | HS Everett | Oil Tanker | 2008 |
| 83 | 9410894 | Valour | Oil Tanker | 2009 |
| 84 | 9411020 | Bratsk | Oil Tanker | 2009 |
| 85 | 9412335 | Bolero | Oil Tanker | 2010 |
| 86 | 9412347 | Leo | Oil Tanker | 2011 |
| 87 | 9412359 | Belgorod | Oil Tanker | 2010 |
| 88 | 9413547 | Altair | Oil Tanker | 2009 |
| 89 | 9413559 | Antarktika | Oil Tanker | 2009 |
| 90 | 9413561 | Alliance | Oil Tanker | 2009 |
| 91 | 9413573 | Atlas | Oil Tanker | 2009 |
| 92 | 9418494 | Zaliv Aniva | Oil Tanker | 2009 |
| 93 | 9421972 | Saturn | Oil Tanker | 2010 |
| 94 | 9422457 | Blossom | Oil Tanker | 2010 |
| 95 | 9436941 | Yi Meng Shan | Oil Tanker | 2010 |
| 96 | 9481910 | Port Olya 3 | General Cargo / Multi Purpose | 2011 |
| 97 | 9511387 | Olympus | Oil Tanker | 2010 |
| 98 | 9511521 | Meridian | Oil Tanker | 2010 |
| 99 | 9522324 | Sierra | Oil Tanker | 2011 |
| 100 | 9610781 | Zenith | Oil Tanker | 2012 |
| 101 | 9610793 | Georgy Maslov | Oil Tanker | 2012 |
| 102 | 9610808 | Anatoly Kolodkin | Oil Tanker | 2013 |
| 103 | 9610810 | Viktor Bakaev | Oil Tanker | 2013 |
| 104 | 9630004 | Velikiy Novgorod | LNG Tanker | 2014 |
| 105 | 9778313 | Marshal Vasilevskiy | FSO Gas Unit | 2018 |
| 106 | 9826902 | Galaxy | Oil Tanker | 2019 |
| 107 | 9849887 | La Perouse | LNG Tanker | 2020 |
| 108 | 9864837 | Mulan | LNG Tanker | 2024 |
| 109 | 9953523 | North Sky | LNG Tanker | 2024 |
REGULATORY IMPACT ANALYSIS STATEMENT
(This statement is not part of the Regulation.)
Issues
- Individuals and entities based in Russia and in third countries continue to engage in sanctions circumvention tactics that aim to supply Russia with materials, services, goods, technologies, revenue and expertise that support the Russian regime’s military complex and defence industrial base. This supply enables Russia’s military actions and its illegal aggression towards Ukraine. Action must be taken to address these evasion tactics and circumvention activities.
- Russia has made use of a so-called “shadow fleet” of vessels to circumvent sanctions, which engage in deceptive shipping practices, have inadequate insurance, are ageing and pose environmental and safety risks.
- Additionally, individuals and entities continue to engage in activities that support Russia’s unlawful aggressions in Ukraine, including the planning and implementation of filtration points in Russian-occupied Ukraine, the unlawful deportation and forced transfer of Ukrainian children and the dissemination of disinformation and propaganda designed to manipulate public opinion and justify Russia’s illegal actions.
- The oil and gas sectors remain major sources of revenue for Russia, which helps financially sustain Russia’s military industrial complex. Russia continues to look for new ways to maintain their energy operations and these revenues.
Background
Situation in Ukraine
On February 24, 2022, Russia began a full-scale military invasion of Ukraine, launching attacks on many cities. Russia continues to wage a war of aggression against Ukraine, and to commit atrocities against Ukrainians.
Experts, including from the Organization for Security and Cooperation in Europe Moscow Mechanism fact-finding missions, the Independent International Commission of Inquiry on Ukraine and the United Nations (UN) Office of the High Commissioner for Human Rights, have concluded that Russia is committing serious human rights violations, war crimes, possible crimes against humanity and conflict-related sexual violence. As of January 2025, the UN Human Rights Monitoring Mission in Ukraine has confirmed that at least 12 456 civilians have been killed and over 28 382 were injured since February 24, 2022. Furthermore, 660 medical facilities and 1 275 educational facilities in Ukraine have been damaged or destroyed by Russia’s military since the invasion.
“Filtration points” were established on Russian-held Ukrainian territory that the Russian regime uses to triage Ukrainians based on connection to the Ukrainian state. Open sources such as the BBC report that journalists and those with connections to Ukraine’s military are targeted and are subject to interrogation and torture. President Putin’s military invasion has also been paired with significant malicious cyber operations and disinformation campaigns that falsely portray the West as the aggressor, falsely claiming that Ukraine is developing chemical, biological, radiological and/or nuclear weapons with North Atlantic Treaty Organization (NATO) support.
The forced displacement of Ukrainian children has been a central concern since the Russian 2014 invasion and has increasingly gained media attention since the outbreak of the full-scale war in 2022. Thousands of Ukrainian children are reported to have been illegally deported or forcibly transferred to facilities in Russia and Russian-held Ukrainian territory. To date, only a few hundred children have successfully returned to Ukraine from Russia.
Russian propaganda about the war in Ukraine seeks to shape domestic and international perceptions in Russia’s favour. The regime achieves this by using various disinformation techniques, ranging from misleading narratives about the conflict’s origins to outright denial of Russia’s actions on the ground. The coalition of countries supporting Ukraine, including the G7 and European countries, is engaging in intense diplomacy to support Ukraine across a number of areas, including combatting Russian disinformation. Specifically, the G7 Rapid Response Mechanism is strengthening G7 coordination to identify and respond to foreign threats to democracies, such as disinformation.
The export of sensitive technologies to Russia has become a critical issue, as these technologies can bolster Russia’s military capabilities and undermine the effectiveness of international sanctions. Despite extensive export controls and other economic measures imposed by Canada and international partner governments, Russia has exploited illicit networks and third countries to acquire advanced technologies, including dual-use items with both civilian and military applications. These technologies are crucial for maintaining Russia’s weapons systems, allowing it to continue perpetrating its illegal war.
There is a historically unprecedented volume of sanctions on Russia, its key industries and resources, and perpetrators and supporters of the war in Ukraine. Russian officials, individuals and entities have deployed various methods to circumvent these prohibitions. They have used logistics companies — including airline companies — to transport prohibited goods from third countries and set up businesses in third countries to facilitate this evasion. Of note, Russia is heavily reliant on its oil and gas resources to fund the war, making regulations and restrictions on this industry critical to curtailing Russia’s access to funds and resources.
The Russian “shadow fleet,” a network of vessels and various supporting entities around the world, used to transport sanctioned goods and commodities, is central to Russia’s efforts to evade or otherwise circumvent sanctions. These vessels often intentionally disable or manipulate their automatic identification systems, have substandard maintenance, unclear ownership, inadequate insurance coverage, and engage in dangerous ship-to-ship transfers. The International Maritime Organization (IMO) Resolution A.1192(33), “Urging Member States and All Relevant Stakeholders to Promote Actions to Prevent Illegal Operations in the Maritime Sector by the ‘Dark Fleet’ or ‘Shadow Fleet,’” calls on states to take a range of actions to prevent this type of activity. Canada has signed a United Kingdom-led “Call to Action” on the shadow fleet, which has been signed by 50 other states. The international coalition supporting Ukraine has increased efforts to counter the shadow fleet by enhancing maritime surveillance, sanctioning vessels involved, and undertaking outreach with industry, flag states and port states.
Russia’s unprovoked and unjustifiable aggression against Ukraine violates international law, jeopardizes stability in the region and puts countless innocent lives at risk. It also threatens the values and principles that underpin the rules-based international system, including every state’s right to sovereignty and self-determination. Canada is steadfast in its commitment to support Ukraine’s sovereignty, territorial integrity, independence, and its efforts towards a just and sustainable peace. Alongside international partner governments, Canada has unequivocally condemned Russia’s illegal and egregious actions.
International response
The coalition of countries supporting Ukraine includes, but is not limited to, the G7 and European countries. This group is working to support Ukraine across a number of areas, including by contributing to energy security, nuclear safety, food security, humanitarian assistance, combatting Russian disinformation, imposing sanctions and economic measures, asset seizure and forfeiture, military assistance, ensuring accountability and fostering socio-economic recovery and reconstruction.
Certain countries have not participated in sanctions efforts targeting Russia in the wake of the 2022 invasion of Ukraine and appear to be directly and indirectly supplying goods and services that would otherwise be prohibited by coordinated international sanctions.
Canada’s response
Following Russia’s illegal occupation and attempted annexation of Crimea in March 2014, the Government of Canada, in tandem with partners and allies, enacted sanctions through the regulations under the Special Economic Measures Act (SEMA). These sanctions impose dealings prohibitions (an effective asset freeze) on listed individuals and entities supporting or enabling Russia’s violation of Ukraine’s sovereignty. Any person in Canada and Canadians outside Canada is prohibited from dealing in the property of, entering into transactions with, providing services to, or otherwise making goods available to persons listed under schedules 1, 2 or 3 of the Special Economic Measures (Russia) Regulations (the Russia Regulations).
In total, Canada has committed over $19.5 billion in financial, military, humanitarian, development, security, stabilization and immigration assistance in response to Russia’s full-scale invasion on February 24, 2022. Canada remains committed to supporting Ukraine’s stability, security and sovereignty, as it resists Russia’s war of aggression.
Since 2014, in coordination with its partners, Canada has imposed sanctions on over 3 000 individuals and entities in Russia, Belarus, Ukraine and Moldova, linked to their support of the illegal invasion of Ukraine. In addition, Canada has implemented targeted restrictions against Russia and Belarus in financial, trade (goods and services), energy and transport sectors. Canada is part of the Oil Price Cap Coalition, the G7 diamond import ban and ongoing efforts to use the proceeds from Russian sovereign assets to help Ukraine.
Unlawful deportation and forced transfer of Ukrainian children
Canada is the co-chair of the International Coalition for the Return of Ukrainian Children, which was launched in Kyiv, Ukraine, on February 2, 2024. Canada is working closely with Ukraine to support dialogue and information exchange and to coordinate key messages between key stakeholders on this issue.
On October 30 and 31, 2024, Canada co-hosted the Ministerial Conference on the Human Dimension of Ukraine’s 10-Point Peace Formula (a formula that respects the country’s sovereignty and territorial integrity, the UN Charter, and international law) in Montréal with the Ukrainian and Norwegian Ministers of Foreign Affairs. At the conference, the ministers announced the Montréal Pledge, concrete steps to help return prisoners of war, unlawfully detained civilians and deported children, including support as these people reintegrate into their daily lives.
Disinformation and propaganda agents
Canada is a leader in the international effort to counter disinformation. Canada has established Rapid Response Mechanism Canada, the permanent secretariat to the G7 Rapid Response Mechanism, which is a team dedicated to understanding, monitoring and detecting Russian and other state-sponsored disinformation. Through diplomacy, Canada will continue to raise awareness of state-sponsored information manipulation operations and coordinate international responses to foreign threats to democracy. Sanctions are also central to these coordinated efforts to counter Russian hybrid warfare, in which state-generated disinformation is an essential component. Canada’s sanctions have targeted over 150 Russian disinformation agents to date, sending a strong signal that there are consequences to manipulating and distorting information. This pioneering effort has been recognized and leveraged by Canada’s like-minded partners.
Sanctions circumvention in third countries
In order to address sanctions evasion, Canada amended the Russia Regulations in February 2024 to strengthen its sanctions regime by allowing the listing of persons in third countries complicit in the violation of Ukraine’s sovereignty and territorial integrity, including persons that help Russia to evade or circumvent sanctions measures. The NATO Washington Summit Declaration included significant references to specific states — the People’s Republic of China, the Democratic People’s Republic of Korea and Iran — that enable Russia’s war against Ukraine.
Oil and gas
Canada and G7 partners have sought to limit Russian access to revenue from the oil and natural gas sector. Canada prohibits the import of any Russian crude oil, refined petroleum products and gaseous hydrocarbons, as well as the export of goods related to oil exploration and production and related services. Canada also prohibits the provision of services related to the marine transport of oil purchased above the oil price cap. Finally, Canada prohibits a wide range of services from being provided in relation to the Russian energy, manufacturing and transportation sectors.
Prohibitions on vessels
Several countries including Canada have put in place prohibitions on different categories of ships linked to Russia from entering their ports. Since 2022, Canada’s Russia Regulations have banned certain ships from docking in or passing through Canada. This applies to ships registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a listed person. This prohibition aims to prevent Russia from benefitting from maritime trade with Canada.
Sensitive technology
Canada’s Restricted Goods and Technologies List (RGTL) serves as a vital tool in preventing the unauthorized export of sensitive goods and technologies. The list identifies items that are subject to trade prohibitions due to their potential military applications or strategic value. In parallel to these amendments, the RGTL, which is referenced in the Russia Regulations, is being updated and expanded to prohibit a wider range of sensitive goods and technologies from being exported to Russia.
Objective
These measures aim to
- Undermine Russia’s ability to conduct military operations in Ukraine by targeting Russia’s military-industrial base and disrupting the flow of sensitive technology to Russia;
- Deter entities in third countries from directly or indirectly supporting Russia’s war of aggression and facilitating sanctions circumvention by providing Russia with prohibited goods and services;
- Undermine and expose persons associated with a range of crimes and abuses, including the forced deportation of Ukrainian children, the Kremlin’s disinformation and propaganda campaigns, and the planning and implementation of filtration points in Russian-occupied Ukraine;
- Disrupt the Russian regime’s support structures, including by exposing senior Russian government officials, oligarchs and members of President Putin’s family;
- Disrupt the sanctions circumvention efforts of the Russian “shadow fleet,” including the covert transport of sanctioned goods and technologies, and enforce adherence to international maritime law and standards; and,
- Curtail Russia’s ability to profit from its oil and gas exploration and production.
Description
Amendments to the list of sanctioned persons
The amendments add 32 individuals and 44 entities to Schedule 1 of the Russia Regulations.
These persons include
- Individuals and entities in Russia supporting Russia’s military-industrial base by supplying or facilitating the transport and shipping of military equipment, key technology and electrical components. These also include entities controlled by the Ministry of Defence of the Russia Federation and entities implicated in the increasing military cooperation between Russia and the Democratic People’s Republic of Korea (DPRK);
- Entities in third countries, including in Iran and the People’s Republic of China, supporting directly or indirectly Russia’s defence industries;
- Entities involved in sanctions circumvention, including in the airline and insurance industries that facilitate access to sanctioned goods and that contribute to Russia’s revenue, all in the service of Russia’s war efforts;
- Individuals and entities associated with a number of abuses, including the forced deportation of Ukrainian children, the Kremlin’s disinformation agents, and individuals involved in the planning and implementation of filtration points in Russian-occupied Ukraine; and
- Senior Russian government officials, oligarchs and members of President Putin’s family.
Any person in Canada or Canadian outside Canada is thereby prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed individuals and entities (persons) — unless explicitly authorized by a permit granted on an exceptional basis or an exception in the Russia Regulations. These measures will also render listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act. Under the Russia Regulations, listed persons may apply to the Minister of Foreign Affairs to have their name removed from the Schedule of designated persons. The Minister must determine whether there are reasonable grounds to make a recommendation to the Governor in Council for removal.
Amendments to strengthen existing prohibitions on ships
The amendments add a new Schedule 1.1 containing a list of ships to improve enforcement of the existing docking and passage prohibition in Section 3.04. To combat efforts to evade the restrictions by frequently changing names, the ships are being listed by their International Maritime Organisation number (IMO number). The new criterion added to Section 2.01 provides that the ships added to Schedule 1.1 are those where the Governor in Council, on the recommendation of the Minister, is satisfied there are reasonable grounds to believe are transporting or have transported property or goods on behalf of or for the benefit of Russia or a person in Russia.
A new provision will be made to allow applications to the Minister under the Russia Regulations to have ships removed from the schedule. Upon receipt of an application, the Minister must decide whether there are reasonable grounds to recommend to the Governor in Council that the ship’s IMO number be removed.
The amendments add an initial list of 109 vessels to Schedule 1.1. The ships listed in this amendment have been involved in the transport of goods (such as crude oil, Liquified Natural Gas, or arms and related material) on behalf of or for the benefit of Russia or a person in Russia. All of these ships have been subject to sanctions by at least one of the United States, United Kingdom or European Union.
Amendments to other prohibitions
The title of the existing prohibition in Section 3.05 related to petroleum oils and gases is being amended to clarify that it applies equally to Liquified Natural Gas (LNG).
Additional amendments are being made to certain HS codes in Schedule 7, which contains a list of goods subject to the prohibition in Section 3.09 on goods used for the manufacture of weapons. Previous versions of the Schedule contained HS codes at both the two- and six-digit level (item 38) and at the four- and six-digit level (item 39). To facilitate its effective implementation, items 38 and 39 will be amended to clarify that the prohibitions apply at the highest digit HS code included in the Schedule.
Regulatory development
Consultation
Global Affairs Canada regularly engages with relevant stakeholders, including civil society organizations, cultural communities and other like-minded governments, regarding Canada’s approach to sanctions implementation.
With respect to the amendments adding individuals and entities and proposing modifications under the current package, public consultation would not be appropriate. Publicizing the names of the persons targeted by sanctions would have potentially resulted in asset flight prior to the coming into force of the amendments.
Modern treaty obligations and Indigenous engagement and consultation
An initial assessment of the geographical scope of the initiative was conducted and did not identify any modern treaty obligations, as the amendments do not take effect in a modern treaty area.
Instrument choice
Regulations are the sole method to enact sanctions in Canada. No other instrument could be considered.
Regulatory analysis
Benefits and costs
The measures included in this package strengthen existing economic measures against Russia, constrain their ability to finance and resource its illegal war, and hold individuals and entities accountable for actions that contribute to Russia’s war in Ukraine.
Based on an initial assessment of available open-source information, it is anticipated that there will not be significant impacts on Canadians and Canadian businesses as a result of these amendments.
The new Schedule of specific vessels will provide the benefit of facilitating enforcement of the general prohibition on docking and passage in Canada. Without the Schedule, enforcement authorities must determine on a case-by-case basis whether a vessel is subject to the general prohibition. The Schedule provides a predetermination of status for a category of vessels that can be used to identify them for purposes of denying them docking and passage.
Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed individuals and entities to their existing monitoring systems, which may result in a minor compliance cost.
Small business lens
Analysis under the small business lens concludes that the amendments could impact Canadians small businesses. The amendments listing new individuals and entities do not impose any new compliance or administrative burden on small businesses in Canada. These amendments prohibit Canadian businesses from dealing with, providing services to, or otherwise making goods available to listed persons, but do not create obligations related to them.
Canadian businesses may seek permits under the Russia Regulations which are granted on an exceptional basis allowing policy space for exemptions. However, Global Affairs Canada does not anticipate any applications resulting from listing these persons or technologies. Canadian small businesses are also subject to the duty to disclose under the Russia Regulations, which would represent a direct compliance requirement. However, as the newly listed persons have no known legitimate linkages with Canada, Global Affairs Canada does not anticipate any disclosures resulting from the amendments.
One-for-one rule
The one-for-one rule does not apply as there is no incremental change in administrative burden on businesses. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act; however, while permits may be granted under the Russia Regulations, on an exceptional basis, given the minimal level of trade with Russia, Global Affairs Canada does not anticipate any permit applications with respect to the amendments.
Regulatory cooperation and alignment
While the amendments are not related to a work plan or commitment under a formal regulatory cooperation forum, they align with actions taken by Canada’s partners and like-minded. Sanctions are most effective when they are applied in a coordinated manner and Canada is working to harmonize efforts internally, and with partners, to facilitate a unified front on sanctions.
Canada’s international partners continue to update their sanction regimes against individuals and entities in Russia and enforce far-reaching financial, trade and investment prohibitions on Russia. Countries and jurisdictions that have sanctioned individuals and entities related to Russia’s military efforts, including circumvention and disinformation, include Australia, the European Union, Japan, New Zealand, Switzerland, the United Kingdom and the United States.
Recent discussions among like-minded governments have reflected the need to target Russian sanctions circumvention and war efforts through targeting of logistics, oil and gas sectors, and third country support for Russia. These amendments align with these objectives.
Effects on the environment
The amendments are unlikely to result in important environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA Directive), a preliminary scan concluded that a SEEA is not required.
Gender-based analysis plus
The subject of economic sanctions has previously been assessed for effects on gender and diversity. Although intended to facilitate a change in behaviour through economic pressure on individuals and entities in foreign states, sanctions under the SEMA can nevertheless have an unintended impact on certain vulnerable groups and individuals. Rather than affecting Russia as a whole, these targeted sanctions impact individuals believed to be engaged in activities that directly or indirectly support, provide funding for or contribute to a violation of the sovereignty or territorial integrity of Ukraine. Therefore, these sanctions are unlikely to have a significant impact on vulnerable groups as compared to traditional broad-based economic sanctions directed toward a state. In so far as sanctions limit Russia’s ability to wage war, women, children and vulnerable groups are likely to benefit from these measures.
Implementation, compliance and enforcement, and service standards
The amendments come into force on the day they are registered.
Consequential to being listed in the Russia Regulations, and pursuant to the application of paragraph 35.1(b) of the Immigration and Refugee Protection Act, the listed individuals would be inadmissible to Canada.
The names of the listed individuals, entities and ships will be available online for financial institutions and other stakeholders to review and will be added to the Consolidated Canadian Autonomous Sanctions List. This will help to facilitate compliance with the Russia Regulations.
The Trade Commissioner Service (TCS) at Global Affairs Canada, abroad and in Canada, continues to assist clients in understanding Canadian sanctions regulations, and notably the impact of the regulations on any activities in which Canadians may be engaged. Global Affairs Canada is also increasing outreach efforts across Canada — including to engage with businesses, universities, and provincial/territorial governments — to enhance national awareness of and compliance with Canadian sanctions.
Global Affairs Canada collaborates with the Canada Border Services Agency for effective enforcement, activating a border lookout when a new prohibition is implemented, as they possess the essential on-the-ground expertise for enforcement to ensure exports do not flow to Russia directly or via third countries.
The prohibitions on ships entering or passing through Canada, including the new list of specific ships, are enforced by a multi-departmental process involving Transport Canada, the Canadian Coast Guard, the Canada Border Services Agency, the Royal Canadian Mounted Police and others.
Under the SEMA, both the Royal Canadian Mounted Police and the Canada Border Services Agency officers have the power to enforce sanctions violations through their authorities as defined under the Customs Act, the Excise Act or the Excise Act, 2001, and sections 487 to 490, 491.1 and 491.2 of the Criminal Code.
In accordance with section 8 of the SEMA, every person who knowingly contravenes or fails to comply with the Russia Regulations is liable, upon summary conviction, to a fine of not more than $25,000 or to imprisonment for a term of not more than one year, or to both: or, upon conviction on indictment to imprisonment for a term of not more than five years.
Contact
Sanctions Bureau
Global Affairs Canada
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Telephone (toll-free): 833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085
Email: sanctions@international.gc.ca