Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2025-141

Canada Gazette, Part II, Volume 159, Number 14

Registration
SOR/2025-141 June 13, 2025

SPECIAL ECONOMIC MEASURES ACT

P.C. 2025-516 June 13, 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

Amendment

1 Part 1 of Schedule 1 to the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in numerical order:

Application Before Publication

2 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

3 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

President of Russia Vladimir Putin continues to wage his illegal invasion of Ukraine, supported by a wide network of government and private sector actors. Individuals, especially those related to Russia’s military-industrial complex and based in Russia, continue to provide direct and indirect support to Russia to enable its illegal aggression toward Ukraine. Moreover, the dissemination of disinformation and propaganda designed to manipulate public opinion and justify Russia’s illegal actions remains an integral part of the Russian Federation’s efforts to undermine Ukraine’s sovereignty and territorial integrity.

The Russian authorities also continue to commit human rights violations against the country’s citizens. In Moscow, authorities have implemented video surveillance and facial recognition systems to facilitate human rights violations in Russia, including arbitrary arrests or detentions. It is reported that these systems are used not only for the repression of peaceful protests, but also to track down and detain draftees seeking to evade mobilization or conscription for Russia’s war in Ukraine.

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. 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 United Nations 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 (HRMMU) 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. In March 2025, the HRMMU reported that the number of civilian casualties in Ukraine increased significantly with at least 164 killed and 910 injured. The number of civilian casualties in March was 50% higher than in February 2025, and more than 70% higher than the same period last year.

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 (G7 RRM) is strengthening G7 coordination to identify and respond to foreign threats to democracies, such as disinformation.

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 toward a just and sustainable peace and 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

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 Russia 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.

Canada’s commitment to promote human rights and democracy in Russia

In response to the death of Russian opposition leader Alexei Navalny in prison in February 2024, the Anti-Corruption Foundation (AFC), founded by Navalny, has recommended imposing sanctions against President Putin’s inner circle. The AFC maintains an open list of more than 7 000 persons with links to the current regime, including 45 listed individuals.footnote 2

Disinformation and propaganda agents

Canada is a leader in the international effort to counter disinformation. Canada has established Rapid Response Mechanism Canada (RRM Canada), the permanent secretariat to the G7 RRM, 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.

Objective

These measures aim to

Description

The amendments add 45 individuals to Schedule 1 of the Russia Regulations.

These persons include

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 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.

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, 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. Therefore, these amendments to the Russia Regulations were not prepublished in the Canada Gazette, Part I.

Modern treaty obligations and Indigenous engagement and consultation

An assessment was undertaken to determine whether the amendments would give rise to modern treaty implications or duty to consult obligations. No implications or obligations were identified.

Instrument choice

Under the SEMA, sanctions are imposed and lifted by regulation. Therefore, regulations are the only available legal instrument for removing a person from the Canadian sanctions list. No other instruments were 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 accountable for actions that contribute to Russia’s war in Ukraine. By calling out these paramilitary groups and their networks, Canada signals strong and public 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. Therefore, it is 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 will result in a minor compliance cost.

Small business lens

Analysis under the small business lens concludes that the amendments will provide additional clarity for Canadian small businesses. The amendments do not impose any new compliance or administrative burden on small businesses in Canada. The 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. Additionally, 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. 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 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 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 allies and like-minded partners. Sanctions are most effective when they are applied in a coordinated manner and Canada is working to homogenize 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 discourse 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.

International obligations

Compliance with Canada’s international commitments was considered in the development of these amendments.

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 strategic environmental and economic assessment 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 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 Russia 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 and territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

G7 states continue to enforce an export ban on various goods to Russia, including specific technologies, arms and related materials. 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.

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 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

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