Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2025-168

Canada Gazette, Part II, Volume 159, Number 19

Registration
SOR/2025-168 August 28, 2025

SPECIAL ECONOMIC MEASURES ACT

P.C. 2025-635 August 28, 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 (1) The portion of subsection 3.12(1) of the Special Economic Measures (Russia) Regulations footnote 1 before paragraph (a) is replaced by the following:

Services — marine transportation of crude oil and petroleum products

3.12 (1) It is prohibited for any person in Canada and any Canadian outside Canada to provide to or for the benefit of Russia or any person in Russia a service referred to in Schedule 10 in relation to marine transportation, including ship-to-ship transfers, of goods set out in column 1 of Schedule 10.01 if

(2) Paragraph 3.12(1)(c) of the Regulations is replaced by the following:

(3) Subsection 3.12(2) of the Regulations is replaced by the following:

Non-application — goods on ship

(2) Subsection (1) does not apply in respect of services provided in relation to any goods that are set out in column 1 of Schedule 10.01 and referred to in any of the Harmonized Commodity Description and Coding System codes or tariff classification numbers that were loaded onto a ship before the date on which this subsection comes into force and unloaded at the port of destination 45 days after that date.

(4) Subsection 3.12(4) of the Regulations is repealed.

2 Item 1476 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

3 Item 1480 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

4 Item 1482 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

5 Item 1488 of Part 1 of Schedule 1 to the Regulations is repealed.

6 Items 1492 to 1494 of Part 1 of Schedule 1 to the Regulations are replaced by the following:

7 Item 1505 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

8 Item 1508 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

9 Item 1510 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

10 Item 1516 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

11 Item 1550 of Part 1 of Schedule 1 to the Regulations is replaced by the following:

12 The portion of item 100 of Schedule 1.1 to the Regulations in the column under the heading “Vessel name” is replaced by the following:
Item Vessel name
100 Shah Ismayil Khatai
13 (1) The portion of item 115 of Schedule 1.1 to the English version of the Regulations in the column under the heading “Vessel name” is replaced by the following:
Item Vessel name
115 Savitri
(2) The portion of item 115 of Schedule 1.1 to the French version of the Regulations in the column under the heading “Type” is replaced by the following:
Article Type
115 Pétrolier
14 The portion of item 296 of Schedule 1.1 to the Regulations in the column under the heading “Vessel name” is replaced by the following:
Item Vessel name
296 Vladimir Vinogradov
15 The portion of item 300 of Schedule 1.1 to the Regulations in the column under the heading “Vessel name” is replaced by the following:
Item Vessel name
300 Okeansky Prospect
16 The portion of items 302 and 303 of Schedule 1.1 to the Regulations in the column under the heading “Vessel name” is replaced by the following:
Item Vessel name
302 Vladimir Arsenyev
303 Nikolay Zadornov

17 Schedule 5 to the Regulations is amended by replacing the reference after the heading “SCHEDULE 5” with the following:

(Subsection 3.05(1))

18 The Regulations are amended by adding, after Schedule 10, the Schedule 10.01 set out in the schedule to these Regulations.

Application Before Publication

19 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

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

SCHEDULE

(Section 18)

SCHEDULE 10.01

(Subsections 3.12(1) and (2))

Price Cap on Goods
Item

Column 1

Goods

Column 2

Harmonized Commodity Description and Coding System Code or Tariff Classification Number

Column 3

Price Cap (USD per Barrel)

1 Crude oil 2709 $47.60
2 High-value petroleum products, including gasoline, motor spirits, aviation spirits, motor fuel blend stocks, gasoil and diesel fuel, kerosene and kerosene-type jet fuel, and vacuum gas oil
  • 2710 12 90 11
  • 2710 12 90 14
  • 2710 12 90 16
  • 2710 12 90 19
  • 2710 12 90 20
  • 2710 12 90 92
  • 2710 12 90 93
  • 2710 12 90 94
  • 2710 19 99 11
  • 2710 19 99 19
  • 2710 19 99 23
  • 2710 19 99 24
  • 2710 19 99 25
  • 2710 19 99 29
  • 2710 19 99 93
  • 2710 19 99 95
  • 2710 19 99 99
$100.00
3 Low-value petroleum products, including residual fuel oils, naphthas, and waste oils 2710, except for goods described in the codes set out in item 2, column 2 $45.00

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

Revenues from Russia’s oil industry continue to play a critical role in financing the Russian Federation’s blatant violation of international law and ongoing violation of Ukraine’s sovereignty and territorial integrity that began with Russia’s illegal annexation of Crimea in 2014 and continued with its unprovoked and unjustifiable full-scale military invasion of Ukraine on February 24, 2022.

In 2022, the G7, Australia and New Zealand (the “Oil Price Cap Coalition”) set a price cap for Russian crude oil sold on the open market of US$60 per barrel to restrict the flow of oil revenues into Russia’s war chest. However, the effectiveness of the price cap is progressively being challenged by a decline in global oil prices, including Russian crude oil (Urals), as well as by the expectation of a well-supplied market of crude oil in the future. To further limit Russia’s ability to wage its unjustified war, the Government of Canada is amending the Special Economic Measures (Russia) Regulations (the Russia Regulations) to lower the oil price cap for Russian crude oil.

Background

On February 24, 2022, Russia initiated an unjustified full-scale military invasion of Ukraine, launching combined attacks (from land, air, and sea) on many cities, in violation of the United Nations (UN) Charter and international law. Three and a half years later, Russia continues to wage a war of aggression against Ukraine, and to commit atrocities against Ukrainians.

Experts 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 May 2025, the UN Human Rights Monitoring Mission in Ukraine has confirmed at least 13 341 civilians have been killed and over 32 744 have been 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.

The oil price cap

Given the importance of oil and gas revenue to Russia’s economy and its war effort, Canada and the members of the Oil Price Cap Coalition (the “Coalition”) have sought to limit Russian access to revenue from the energy sector through various measures. Under the Russia Regulations, Canada prohibits the import of any Russian crude oil, refined petroleum products and gaseous hydrocarbons, and prohibits the export of goods related to oil exploration and production in Russia.

In June 2022, in an effort to further limit Russian revenues while preserving stability in the global oil market, G7 leaders agreed to a comprehensive prohibition of all services that enable the transportation of Russian seaborne crude oil and petroleum products globally, unless the oil is purchased at or below a price to be agreed upon in consultation with international partners (the “price cap”).

On December 7, 2022, following an agreement between Coalition members, Canada amended the Russia Regulations to prohibit the provision of eight services in relation to the maritime transport of Russian crude oil unless the oil is purchased at or below the price outlined in the G7+ Coalition Oil Price Cap List. The oil price cap limits the price at which Russian seaborne crude oil can be sold if the seller wants to use services (e.g. shipping) from service providers (e.g. transportation/logistics companies) based in Coalition countries. Therefore, if Russian oil is sold at a price above the cap, service providers in Coalition countries are prohibited from providing any services. The intention of setting a price cap is to allow Russian oil to flow to international markets (to ensure market stability) using service providers from Coalition countries, but at a lower price, which helps to limit Russia’s revenues from oil exports.

On February 5, 2023, this prohibition was extended to the maritime transport of certain Russian petroleum products.

At the time of implementation, the Coalition had agreed on the following price caps, noting that they would have to be reviewed periodically to adapt to evolving market pressures:

Russian crude oil prices have declined from a peak of around US$100 per barrel in 2022 to a range of US$50–US$68 per barrel today. In the two months prior to the escalation of the Israel–Iran conflict, the price had dropped below the existing price cap level consistently, rendering the cap ineffective in curbing Russian oil revenues relative to market prices.

On July 18, 2025, the European Union (EU) announced that it would lower the price cap for crude oil from US$60 to US$47.60 per barrel, in light of changes to current global oil prices. The EU further announced that it would move from a fixed price mechanism to a floating mechanism that is linked to the average market price of Russian oil. These changes introduce an automatic and dynamic mechanism to modify the oil price cap to ensure that the price cap remains below market prices. The United Kingdom (U.K.) announced on the same day that it would lower its price cap to US$47.60 in line with the EU’s initial price level; however, the U.K. has not indicated whether it will follow the EU’s floating cap mechanism. There is currently no consensus within the Coalition on whether to align the price caps with those of the EU and U.K.

Following commitments made at the G7 Finance Ministers and Central Bank Governors’ meeting in May 2025 to explore all possible options to maximize pressure on Russia, such as further ramping up sanctions, Canada agreed to lower its price cap for Russian crude oil from US$60 a barrel to US$47.60, but without implementing the EU’s dynamic mechanism. The Coalition price cap set for all other petroleum products is maintained. Canada remains a member of the Coalition and intends to follow future price adjustments agreed upon by the Coalition, but may choose to set a lower price cap with other members of the Coalition.

Objective

The objective of the amendments is to reduce Russia’s revenues and ability to fund its war of aggression while limiting the impact on global energy prices, particularly for low- and middle-income countries.

Description

The amendments update section 3.12(1)c) of the Russia Regulations and create a new schedule, Schedule 10.01, to display all oil cap prices instead of referring to the G7+ Coalition Oil Price Cap List.

The amendments lower the price cap per barrel for crude oil from US$60 to US$47.60.

The amendments also include a 45-day non-application period in respect of services provided in relation to goods that were loaded onto a vessel and unloaded at the port of destination within 45 days after the day the amendments are registered. This non-application period was also implemented when the oil price cap was first introduced in December 2022.

The amendments further repeal exceptions to the service prohibition related to the importation of crude oil and petroleum products into the Republic of Bulgaria and the Republic of Croatia. These exceptions were in place only for a specified period and have since expired.

The amendments also include non-substantive changes to make corrections to the names and dates of birth of individuals and the names of vessels previously listed, and to address a double listing. These corrections, which do not change the validity of the initial listings, consist of updating the dates of birth for 10 previously listed individuals; removing the listing of item 1488, Vladimir Sergeevich LISIN, in Schedule 1, Part 1, as this individual is currently designated twice under the Russia Regulations; correcting the name format of 5 vessels to add adequate spacing; correcting the name of one vessel in the English version of the Regulations to match the correct name in the French version; and correcting the middle name of the individual listed at item 1550 of Schedule 1, Part 1. These changes are corrections for precision and accuracy based on information obtained by Global Affairs Canada and will not have any appreciable impact on the effect of the existing sanctions measures.

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 the implementation of sanctions.

To date, consultations with industry stakeholders have not raised notable issues or concerns, as the Canadian industry footprint for the targeted services is minimal.

Modern treaty obligations and Indigenous engagement and consultation

In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an analysis was undertaken to determine whether the amendments are likely to give rise to modern treaty obligations. The assessment examined the geographic scope and subject matter of the proposal in relation to modern treaties in effect and no obligations in respect of modern treaty obligations were identified.

Instrument choice

The Government of Canada has opted to use sanctions as one of its foreign policy tools. The Parliament of Canada has enacted legislation authorizing the imposition of sanctions through the United Nations Act, the Special Economic Measures Act (SEMA), and the Justice for Victims of Corrupt Foreign Officials Act.

Canada has established a rigorous due diligence process to consider and evaluate possible cases that may warrant the use of sanctions. While the sanctions imposed to date have helped to increase the pressure to further hinder and deter Russia’s war efforts, stronger and more effective measures are needed through the SEMA. Since lowering the crude oil price cap is being undertaken by a subgroup of the G7+ Coalition, this amendment cannot be referenced in the G7+ Coalition Oil Price Cap List and must be included directly in the Russia Regulations. While bringing all cap prices into a Schedule of the Regulations will require regulatory amendments to update price caps in the future, be they the result of an agreement among Coalition members or of an agreement between a subset of countries, a regulatory approach was chosen for ease of reference and maximum clarity on which prices apply. Furthermore, updates to the price caps are expected to be infrequent.

It is important that listings under the SEMA be accurate and up to date. Listings may have to be updated as new information is obtained, as is the case for the date of birth of the 10 individuals previously listed.

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 existing available legal instrument for adjusting the oil price cap and correcting the dates of birth for the 10 listed individuals. No non-regulatory options were considered.

Regulatory analysis

Benefits and costs

These amendments to the Russia Regulations will strengthen existing economic measures against Russia, further constrain Russia’s ability to finance and resource its unjustified war in Ukraine, and discourage individuals and entities from contributing, directly or indirectly, to Russia’s war efforts. By imposing this new price cap, Canada will contribute to efforts to disrupt Russia’s war economy and bring pressure to end the war and the violation of Ukraine’s sovereignty.

In 2024, oil and gas revenues made up 30% of total Russian federal revenues. While it is complex to disentangle the impacts of sanctions, and wider market dynamics, it is a fact that Russia’s oil and gas revenues dropped 53% from May 2022 to May 2025. While sanctions measures have covered oil and gas products, including pipeline gas and LNG, the oil price cap is a targeted measure for seaborne Russian-origin crude and oil products. There are some estimates showing Russia has foregone US$142 billion of oil export revenues since March 2022,footnote 2 which indicates that Coalition actions, including the oil price cap, are having an impact on Russian government revenues.

Based on an assessment of available open-source information and consultations within the Government of Canada, it is believed that the lower price cap for crude oil would be unlikely to cause significant spikes in the price of oil. Given that Canada already prohibits the direct import of Russian oil and petroleum products, and Canadian companies do not provide services related to the movement of Russian oil, it is unlikely that lowering the price cap will have a direct impact on Canada or Canadian businesses. Canadian oil is primarily exported to the U.S., which is a member of the Coalition. Canadian oil exports on the Trans Mountain Pipeline are sold to markets that also import Russian oil. However, Canada and Russia export different grades of crude oil that do not compete directly with one another, so it is unlikely that changes to Russian oil flows will have a direct impact on Canadian businesses. Global Affairs Canada does not have data to ascertain if any Canadian businesses are currently providing maritime insurance or financial services to tankers transporting Russian oil above the new oil price cap. However, given Canada’s existing sanctions in relation to Russian oil transactions, Global Affairs Canada is of the opinion that it is highly unlikely that any Canadian businesses currently provide such services.

The new price cap level remains higher than Russia’s breakeven cost of production, maintaining the incentive for Russia to keep producing and exporting its oil. Russian seaborne exports are around 7% of global supply, which is significant. Global oil markets and the Canadian economy could be impacted if a large volume of Russian seaborne oil exports is taken off the market. However, reports from the International Energy Agency (IEA) show that the market is well supplied, with weak demand growth and growing supply from OPEC and non-OPEC suppliers. Significant impacts on the global oil market are considered unlikely, given current market conditions.

Lowering the oil price cap for crude oil may shift Russian trade towards using its shadow fleet. The Russian “shadow fleet” is a network of vessels and various supporting entities around the world used to transport sanctioned goods and commodities. It is central to Russia’s efforts to evade or otherwise circumvent sanctions. The automatic identification systems of these vessels are often intentionally disabled or manipulated; the vessels have substandard maintenance, unclear ownership, and inadequate insurance coverage; and operators engage in dangerous ship-to-ship transfers. This risk can be lessened with continued action against these vessels and their enablers. To date, Canada has listed entities in the oil and gas industry that are enabling shadow fleet activities (shipping, insurance, operators), in addition to listing more than 300 vessels. Canada has also created a shadow fleet task force under the auspices of its G7 Presidency to enhance monitoring and detection and to otherwise constrain the use of shadow fleets engaged in illegal, unsafe or environmentally perilous activities.

Canadian businesses may seek permits under the Special Economic Measures Permit Authorization Order to allow them to perform a specified activity prohibited by the Russia Regulations. Such permits are granted on an exceptional basis. Global Affairs Canada does not anticipate any applications resulting from these amendments. There have been no permit requests since the oil price cap was first introduced in December 2022. Canadian banks and financial institutions must comply with Canada’s sanctions laws and conform to the new price cap. Compliance includes meeting the obligation to report instances where there are reasonable grounds to suspect a transaction is linked with sanctions evasion. Further, the Minister of Finance has also issued a directive flagging all transactions originating from, or bound for, Russia as high risk, triggering the implementation of enhanced due diligence measures. Consultations with the insurance sector indicate that Canada is not a major source of maritime insurance and Canada’s banking sector is not believed to be providing financial services directly to shipping companies transporting Russian oil. Financial institutions may be providing services indirectly, and in those instances, they are obligated to have appropriate mechanisms in place to ensure that transactions comply with the new price cap. Given the measures already in place, any incremental costs to Canadian stakeholders resulting from the revised oil price cap are expected to be minimal.

The incremental cost to the Government of Canada to administer and enforce these amendments will be minimal. The Canadian Border Service Agency (CBSA) and the Royal Canadian Mounted Police (RCMP) may incur a small cost to update their relevant systems to include the new price cap imposed through these amendments.

Small business lens

Analysis under the small business lens concludes that it is unlikely that lowering the price cap will have a direct impact on any Canadian small businesses, given that Canada already prohibits the import of Russian oil and petroleum products, and it is unlikely that Canadian companies provide services related to the movement of Russian oil.

Canadian small businesses are also subject to the duty to disclose under the Russia Regulations, which represents a direct compliance requirement. However, as it is believed that it is highly unlikely that any Canadian small businesses currently provide such services as there is no record of these tankers entering Canada and as there is no data available to ascertain any links with Canadian companies, 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 the administrative burden on business. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act, and while permits may be granted under the Special Economic Measures Permit Authorization Order on an exceptional basis, Global Affairs Canada does not anticipate any permit applications with respect to the amendments, given the minimal level of trade with Russia.

Regulatory cooperation and alignment

The amendments are aligned with efforts made by the EU and the U.K. 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 in regard to sanctions.

Although Canada’s approach to the oil price cap is taken only with a subset of Coalition members, the Coalition as a whole remains oriented towards its objective of curbing Russian oil revenues to limit Russia’s ability to wage its unjustified war against Ukraine.

International obligations

Compliance with Canada’s international obligations was considered in the development of this initiative.

Effects on the environment

The amendments are unlikely to result in significant environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA), 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 a key economic sector that is generating revenue used by Russia to finance its continued violation of the sovereignty and 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, individuals vulnerable to gender-based discrimination and children 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. The amendments include a 45-day non-application period in respect of services provided in relation to goods that were loaded onto a vessel and unloaded at the port of destination within 45 days after the day the amendments are registered.

The Trade Commissioner Service at Global Affairs Canada, abroad and in Canada, continues to assist clients in understanding Canadian sanctions regulations, notably, the impact of regulations on any activities in which Canadians may be engaged. Global Affairs Canada is also increasing outreach efforts across Canada through presentations and other events — including to engage with businesses, universities, and provincial/territorial governments — to enhance national awareness about and compliance with Canadian sanctions.

Under the SEMA, RCMP and CBSA 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. Potential violations of the oil price cap should be reported to the RCMP.

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.

The G7+ Coalition Oil Price Cap List will be taken offline when the amendments come into force, as all cap prices will thereafter be included in Schedule 10.01 of the Regulations.

Contact

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