Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2025-62

Canada Gazette, Part II, Volume 159, Number 6

Registration
SOR/2025-62 March 1, 2025

SPECIAL ECONOMIC MEASURES ACT

P.C. 2025-264 March 1, 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 Part 1 of Schedule 1 to the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in numerical order:

2 Part 2 of Schedule 1 to the Regulations is amended by adding the following in numerical order:

Application Before Publication

3 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

4 These Regulations come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

The Russian Federation continues to violate the sovereignty and territorial integrity of Ukraine, including through the use of paramilitary groups. Specifically, Russian paramilitary groups as well as their supporting front companies, are used by Russia as a tool of foreign policy and malign influence, gaining the Kremlin political leverage and resources to maintain its war in Ukraine and advance its anti-Ukraine narrative.

Background

On February 24, 2022, Russia initiated a full-scale military invasion of Ukraine, launching attacks on many cities. Since then, Russia has continued to wage a war of aggression and has committed atrocities against Ukrainians. Russia continues to attack civilian targets such as critical infrastructure in Ukraine, resulting in the loss of access to water, electricity, and communications, and violate the principles of the United Nations (UN) Charter.

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 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 February 2025, the UN Human Rights Monitoring Mission in Ukraine has confirmed at least 12 654 civilians have been killed and over 29 000 were injured since February 24, 2022. Furthermore, 790 medical facilities and 1 670 educational facilities in Ukraine have been damaged or destroyed by Russia’s military since the invasion.

To fund its Ukraine war, the Kremlin has reshaped its economy, mobilized troops and restructured trade and supply partnerships. The Kremlin has also resorted to hybrid warfare to broaden the playing field and harness resources and political support from various regions of the globe. This includes conducting influence and disinformation campaigns, recruitment of soldiers for the Ukrainian front from third countries, as well as taking advantage of the volatile political and security situation abroad for its own political and material gain — most commonly through resource exploitation. The Kremlin conducts these activities abroad by using mercenary and paramilitary organizations, such as the Wagner Group.

The Office of the United Nations High Commissioner for Human Rights (OHCHR), as well as UN-appointed independent human rights experts, have raised repeated concerns about the Wagner Group and its commission of systemic and grave human rights and international humanitarian law violations. There are numerous reports of Wagner Group officers participating in arbitrary detentions, torture, pillaging, looting, summary executions, and sexual violence against women in both Ukraine, and in Central African Republic and Mali, where Russian companies and Wagner Group affiliated companies are extracting resources and gold.

On August 23, 2023, Yevgeny Prigozhin, the leader of the Wagner Group, died in a plane crash. Despite his death, Russian private military companies (PMCs) — and other paramilitary organizations — remain active and influential in Russia. Deputy Defence Minister Yunus-Bek Yevkurov has reportedly visited African capitals to assure officials that the services provided by the Wagner group would not dissipate after Prigozhin’s death.

Several spin-off PMCs and paramilitary groups have emerged from the Wagner core, filling the power vacuum left by Wagner. Wagner itself has also been reconstituted into various subsidiary organizations operating under the Ministry of Defence through a series of contracts. These groups continue to play significant roles in Russia’s military operations and generate revenue and political influence for the Kremlin. Independent investigations also suggest that, like Wagner, these groups are guilty of grave atrocities both in Ukraine and abroad.

The duration of sanctions by Canada and like-minded partners has been explicitly linked to the complete implementation of the Minsk agreements by all parties, and the respect for Ukraine’s sovereignty and territorial integrity, within its internationally recognized borders, which includes Crimea, as well as Ukraine’s territorial sea. The United States, the United Kingdom, Australia, and the European Union have continued to update their sanction regimes against individuals and entities in both Ukraine and Russia, and in third geographies. These paramilitary groups and their activities abroad, which generate revenue for the Kremlin and continuing the fight in Ukraine, stand in direct opposition to Ukraine’s territorial integrity and the objectives of Canada and like-minded partners.

International response

A coalition of countries directly supporting Ukraine includes, but is not limited to, G7 and European countries. This group is working to support Ukraine across several areas, including contributing to energy security, nuclear safety, food security, humanitarian assistance, combatting Russian disinformation, imposing sanctions and economic measures, asset seizure and forfeiture, providing military assistance, ensuring accountability, fostering socio-economic recovery and reconstruction. The international community has also expressed concern about, and sought to address, Russian paramilitary groups and their networks. Paramilitary groups and their networks have been sanctioned by like-minded countries and are under scrutiny in several international fora, including the UN Working Group on the use of mercenaries.

Canada’s response

Canada unequivocally condemns Russia’s illegal and egregious actions. Following Russia’s illegal occupation and attempted annexation of Crimea in March 2014, the Government of Canada, in tandem with like-minded countries, 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 are 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 Regulations).

Since 2014, in coordination with its partners, Canada has imposed sanctions on more than 3 000 individuals and entities in Russia, Belarus, Ukraine and Moldova. This includes sanctions addressing Russian networks in third countries, as well as entities that are supporting Russia in these regions. Canada has also 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. Canada is steadfast in its commitment to support Ukraine’s sovereignty, territorial integrity, independence, and its efforts toward a just and sustainable peace.

Objective

  1. Demonstrate Canada’s commitment to a policy of non-recognition of Russia’s illegal occupation of Crimea, as well as its ongoing concern with Russia’s violations of Ukraine’s sovereignty and territorial integrity.
  2. Expose and sanction Russian paramilitary groups, and their revenue networks, that continue to operate in Russia and support the Kremlin’s illegal war in Ukraine.
  3. Coordinate Canada’s measures with those taken by international partners to provide stronger and more effective measures in responding to Russia’s actions in Ukraine, as well as Russia’s actions abroad that further its foreign policy objectives in Ukraine.

Description

The amendments add 10 new individuals and 21 new entities to Schedule 1 of the Regulations. Listed individuals include 9 leaders of the post-Wagner paramilitary organizations as well as 1 member of affiliated senior Russian military leadership. Listed entities include 9 paramilitary organizations operating in Ukraine and in the Kremlin’s Africa-network as well as 12 affiliated entities that are responsible for resource extraction within this network.

The individuals and entities being added to Schedule 1 of the Regulations are linked to Russia’s illegal annexation of Crimea, and to the continuing violation of Ukraine’s sovereignty and territorial integrity. The activities of these groups are conducted under the guise of the Ministry of Defence and often within formal Russian military formations. These groups, deployed in Ukraine and Africa, continue Wagner’s malicious activities globally and provide an additional lever for the Kremlin in its foreign policy.

Any person in Canada or Canadians outside Canada are 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 regulations. These measures will also render listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act. Under the 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.

Regulatory development

Consultation

Global Affairs Canada regularly engages with relevant stakeholders, including civil society organizations and cultural communities and other like-minded governments regarding Canada’s approach to sanctions implementation.

With respect to the amendments, public consultation would not have been appropriate, as publicizing the names of the listed persons targeted by sanctions would have likely 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 amendments 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. By calling out these paramilitary groups and their networks, Canada signals strong condemnation of this ongoing Russian behaviour.

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions is minimal.

Sanctions targeting specific persons have less impact on Canadian businesses than traditional broad-based economic sanctions, and the amendments will have limited impact on the citizens of the country of the listed persons. Based on an initial assessment of available open-source information, it is believed that the individuals and entities listed have limited linkages with Canada and therefore do not have significant business dealings that are significant to the Canadian economy. It is therefore anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of these amendments.

Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed individuals 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 the listed persons, but do not create obligations related to them.

Canadian businesses may seek permits under the 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. Canadian small businesses are also subject to the duty to disclose under the Regulations, which would represent a direct compliance requirement. However, as the newly listed individuals and entities 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 business. 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 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 partners. 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 sanctions 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 gross and systematic violations of human rights, as well as infringing of Ukraine’s sovereignty and territorial integrity, include Australia, the European Union, Japan, New Zealand, Switzerland, the United Kingdom and the United States.

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 an 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 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 and entities will be available online for financial institutions to review and will be added to the Consolidated Canadian Autonomous Sanctions List. This will help to facilitate compliance with the Regulations.

The Trade Commissioner Service 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.

Under the SEMA, both Royal Canadian Mounted Police and 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 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

Global Affairs Canada
Sanctions Bureau
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085
Email: sanctions@international.gc.ca