Regulations Amending the Special Economic Measures (Moldova) Regulations: SOR/2025-163

Canada Gazette, Part II, Volume 159, Number 19

Registration
SOR/2025-163 August 26, 2025

SPECIAL ECONOMIC MEASURES ACT

P.C. 2025-619 August 26, 2025

Whereas the Governor in Council is of the opinion that the situation in the Republic of Moldova constitutes a grave breach of international peace and security that has resulted or is likely to result 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 (Moldova) 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 (Moldova) Regulations

Amendments

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

2 Part 2 of the schedule 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

Since its invasion of Ukraine in 2022, Russia has hindered Moldova’s democratic reform agenda using malign actors and destabilization campaigns. Russia has also violated Moldova’s sovereignty and territorial integrity, including by stationing 1 500 “peacekeepers” in Moldova’s separatist region of Transnistria, and threatening Moldova’s security as a result of the war in Ukraine (Moldova shares a land border that spans more than 1 200 km with Ukraine).

Ongoing destabilization activities are made possible by the Kremlin’s proxies in Moldova, including Moldovan oligarchs who engage in various acts of corruption. These activities have impacted several of Moldova’s political and economic institutions, as Russia has extended its malign influence campaign in Moldova and beyond. Russia is hindering democratic reforms that the current government of Moldova is pursuing as it seeks European Union (EU) membership. To discourage these activities, the Government of Canada is imposing additional economic measures under the Special Economic Measures (Moldova) Regulations (the Moldova Regulations) on those responsible for destabilization activities.

Background

Situation in Moldova

Russia has wielded long-standing and multifaceted influence in Moldova since the country’s independence from the USSR in 1991. Since Moldova turned toward the West following the election of pro-EU President Maia Sandu in 2020, Moldova has faced increasingly aggressive and sustained hybrid threats from Russia. These include disinformation campaigns, supply restrictions on Russian energy in 2022 and 2025, and efforts to destabilize democratic institutions and electoral processes. Pro-Russia politicians supported through illicit financing from Russia have been used by Moscow to promote disinformation and cause instability in Moldova to advance Russia’s interests, including its objectives as they relate to Ukraine.

As a result, Moldova’s democratic trajectory and prospective European integration have increasingly come under threat from Russian malign influence, especially since Moldova became a candidate for EU accession alongside Ukraine in June 2022. Attempts to interfere in Moldova’s democratic institutions have manifested through corruption, hybrid tactics, disinformation, and other forms of interference. This includes maintaining a presence of 1 500 troops in the separatist region of Transnistria, which borders Ukraine; and separately, financing pro-Russia politicians in the Autonomous Region of Gagauzia. Since 2023, Moldova has held local elections (November 2023), presidential elections (October and November 2024) and a referendum on enshrining EU accession in their constitution (October 2024). During each election, the country faced significant pro-Russia interference.

Moldova’s October 2024 referendum on EU accession narrowly passed with 50.5% support. However, voters in the region of Gagauzia overwhelmingly rejected EU accession, with 95% opposed, suggesting that the region is especially vulnerable to malign interference and is strategically important to Russia’s broader regional objectives. Open-source reporting indicates evidence of vote-buying in Gagauzia during this referendum. These efforts are part of a broader Russian strategy to destabilize democratic institutions and maintain influence over former Soviet states in what Russia perceives to be its sphere of influence.

Pro-Russian officials in the breakaway region of Transnistria have long sought separation from Moldova. Since 1992, Russia has continuously interfered in the region through stationing its troops to guard Russian ammunition depots in Transnistria under the guise of a peacekeeping mission. Russia has used its presence in Moldova to restrain the national government from exercising full sovereignty over Moldovan territory in Transnistria and has threatened military confrontation should Moldova seek to remove them.

Russia cut gas supplies to Transnistria and Moldova on January 1, 2025, in what is widely seen as an attempt to destabilize Moldova further. Transnistria’s MGRES power plant was Moldova’s main source of electricity and stopped production with the halt of Russian gas.

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 its democratic reform, imposing sanctions and economic measures, conducting asset seizure and forfeiture, providing military assistance, ensuring accountability and fostering socio-economic recovery and reconstruction. The coalition has also been vocal in their support for Moldova in the face of Russian attempts to destabilize and threaten Moldova’s sovereignty and territorial integrity.

The EU granted Moldova candidate status in June 2022, as Moldova pursues a substantial domestic reform agenda as part of its path to EU integration. International support for Moldova has included the establishment of a Moldova Partnership Platform, co-chaired by Germany, France, and Romania, which last convened in Chisinau in September 2024, and included the participation of Canada’s Ambassador to Moldova.

Political support has included a June 2018 United Nations (UN) General Assembly Resolution for the complete and unconditional withdrawal of foreign military from the territory of the Republic of Moldova, which Canada co-sponsored. In June 2024, Canada, the United States and the United Kingdom published a joint statement exposing Russia’s subversive activity and electoral interference targeting Moldova. Canada has also contributed to the efforts of the international community to provide political and financial support to the Government of Moldova, including through a $120 million sovereign loan disbursed in 2024–2025. The loan is aimed at supporting the resilience of Moldovan families and Ukrainian refugees, while also fostering sustainable economic growth and climate resilience in Moldova.

Canada’s Response

Canada unequivocally condemns Russia’s actions. Following Russia’s illegal occupation and annexation of Crimea in March 2014, the Government of Canada, in tandem with like-minded countries, enacted sanctions through 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.

Systemic corruption by Moldovan oligarchs, in particular fugitive oligarch Ilan Shor, has impacted several of Moldova’s political and economic institutions, which are being used as instruments of Russia’s malign influence campaign in Moldova, Ukraine, and beyond. For example, Ilan Shor and his associates were key figures in the 2014 Moldovan bank fraud scandal, which ultimately cost Moldovan taxpayers the equivalent of an eighth of the country’s annual GDP. As a result, in June 2023, Canada created the Moldova Regulations under the SEMA. Canada has since implemented two rounds of sanctions against Russian collaborators in Moldova, in May 2023 and October 2023, with a total of 16 individuals and 7 entities listed under the Moldova Regulations to date.

In coordination with its partners, Canada has imposed sanctions on more than 3 300 individuals and entities in Russia, Belarus, Ukraine and Moldova since 2014. 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.

Moldova will hold parliamentary elections on September 28, 2025. Russia’s efforts to undermine this process have been widely documented by the media in the months leading up to the elections. Incumbent President of Moldova Maia Sandu has accused Russia of planning an “unprecedented” campaign to interfere in the country’s elections, warning of a large-scale effort involving illegal financing, cyberattacks and disinformation. Through these tactics, fugitive oligarch Ilan Shor, already sanctioned by Canada, has played a leading role in supporting Russia’s interference campaign aimed at derailing Moldova’s trajectory toward EU membership.

Objective

These amendments to the Moldova Regulations aim to

Description

The amendments list 16 individuals and 2 entities in the Moldova Regulations. These include public figures, such as former parliamentarians, politicians, and media representatives with links to Kremlin-backed fugitive oligarch Ilan Shor, as well as entities tied to Russia’s efforts to destabilize Moldova and advance the Kremlin’s objective of interfering with the territorial integrity of Moldova and Ukraine.

Persons in Canada or Canadians outside Canada are 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 Moldova Regulations. Listed individuals are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act (IRPA).

Under the Moldova 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. Information on the delisting application process is available on Global Affairs Canada’s website.

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.

New sanctions measures are not prepublished in the Canada Gazette, Part I, and public consultation would not have been appropriate for these amendments. Publicizing the names of the listed persons targeted by sanctions could have resulted in asset flight and sanctions evasion prior to the coming into force of the amendments, which could compromise Canada’s foreign policy objectives.

Modern treaty obligations and Indigenous engagement and consultation

In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an initial assessment of the geographical scope of the amendments was conducted to determine whether the amendment would give rise to modern treaty implications, duty to consult obligations, or obligations under the United Nations Declaration on the Rights of Indigenous Peoples Act. No implications or modern treaty obligations were identified, as the amendments do not take effect in a modern treaty area.

Instrument choice

Canada has established a rigorous due diligence process to consider and evaluate possible cases that may warrant the use of sanctions. Given the elements proposed in the package, the SEMA was identified as the instrument of choice.

Sanctions measures under the SEMA are imposed by the Governor in Council, on the recommendation of the Minister of Foreign Affairs, through a regulatory process. Regulations are therefore the only available legal instrument for the amendments. No other instrument could be considered.

Regulatory analysis

Benefits and costs

The amendments strengthen existing economic measures against Russia and Russia-aligned actors in Moldova by constraining their ability to finance and resource Russia’s illegal war in Ukraine.

The complexity and risks associated with the Moldovan market remain significant for all foreign investors. Total trade between Canada and Moldova is minimal. Moreover, the entities identified in these amendments consist of a paramilitary group and a political bloc and are therefore not considerable players in Moldova’s business community. Therefore, Global Affairs Canada has assessed that the commercial impact of this sanctions package on Canadian interests is anticipated to be negligible.

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 countries of the listed persons. Based on an initial assessment of available open-source information, it is believed that listed individuals and entities do not have any significant business ties with Canadian enterprises. Therefore, it is anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of these amendments.

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions is expected to be minimal. The Canada Border Services Agency (CBSA), the Royal Canadian Mounted Police (RCMP) and other departments and agencies would incur a small cost to update their relevant systems to include the persons listed through this amendment.

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. As of August 2024, financial institutions must report transactions suspected of being related to sanctions evasion to the Financial Transactions and Reports Analysis Centre of Canada. Financial institutions also have other legal obligations with respect to monitoring and reporting relevant property ownership, export and import of goods and other activities in connection with sanctioned individuals and entities.

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 Special Economic Measures Permit Authorization Order, 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 Moldova 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 Special Economic Measures Permit Authorization Order on an exceptional basis, given the minimal level of trade with Russia and Moldova, 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 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 Russia-aligned actors in Moldova, 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 has reflected the need to target Russian sanctions circumvention and war efforts through targeting 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 the Regulations.

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, a preliminary scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

None of the newly listed individuals have Canadian citizenship. As a result, the scope of the gender-based analysis plus (GBA+) is limited.

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 and Moldova 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. Insofar 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 Moldova Regulations, and pursuant to the application of paragraph 35.1(b) of the IRPA, 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 Moldova 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.

Under the SEMA, both the RCMP and the CBSA 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 Moldova 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