Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2025-228
Canada Gazette, Part II, Volume 159, Number 24
Registration
SOR/2025-228 November 6, 2025
SPECIAL ECONOMIC MEASURES ACT
P.C. 2025-790 November 6, 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:
- 1552 Yevgeniy Mikhaylovich SEREBRIAKOV (born on July 26, 1981)
- 1553 Alexander Igorevich MISHIN (born on March 18, 1994)
- 1554 Aleksandr Sergeyevich BOLSHAKOV (born on July 23, 1994)
- 1555 Maksim Sergeyevich GALOCHKIN (born on May 19, 1982) (also known as Maksim Sergeevich Sipkin)
- 1556 Mikhail Mikhailovich TSAREV (born on April 20, 1989)
- 1557 Dmitry Sergeyevich BADIN (born on November 15, 1990)
- 1558 Nikolay Alexandrovich KORCHAGIN (born on September 16, 1997)
- 1559 Vitaly Aleksandrovich SHEVCHENKO (born on September 1, 1997)
- 1560 Yuriy Fedorovich DENISOV (born on June 17, 1980) (also known as Yuriy Lukin and Yuriy Dudin)
- 1561 Oleg Vyacheslavovich KARPUSHIN (born on April 8, 1968)
- 1562 Igor Yuryevich CHAIKA (born on December 13, 1988)
- 1563 Dmitriy Vitalyevich MILYUTIN (born on May 30, 1967)
- 1564 Sergei Viktorovich BUDNIKOV (born in 1988)
2 Part 2 of Schedule 1 to the Regulations is amended by adding the following in numerical order:
- 757 Zservers
- 758 XHOST Internet Solutions LP (also known as ISXHost)
- 759 Russian General Staff Main Intelligence Directorate (GRU) 161st Specialist Training text-center (Unit 29155)
- 760 Main Centre for Special Technologies (GTsST) of the Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GU/GRU) (Unit 74455) (also known as Main Centre for Special Development of Ministry of Defence and Military (Unit 74455))
- 761 85th Main Centre for Special Services (GTsSS) of the Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GU/GRU) (Unit 26165)
- 762 Center for Unmanned Systems and Technologies (also known as CUST)
- 763 Arctic LNG 2 LLC (also known as OOO Arctic LNG 2 and LLC ARCTIC LNG 2)
- 764 Gazprom SPG Portovaya Limited Liability Company (also known as Gazprom LNG Portovaya LLC and OOO Gazprom LNG Portovaya)
- 765 A7 LLC (also known as A7 and A7 Limited Liability Company)
- 766 Capital Bank of Central Asia, OJSC (also known as Capital Bank and OJSC Capital Bank of Central Asia)
- 767 Rubicon text-center for Advanced Unmanned Technologies (also known as Rubicon Unit)
3 The portion of items 15, 21, 23, 41, 57, 60, 61, 77, 80, 87 to 89, 100, 101, 116, 120, 128, 158, 194, 195, 231, 242, 278, 280, 281 and 287 of Schedule 1.1 to the French version of the Regulations in the column under the heading “Type” is amended by replacing “Pétrolier” with “Navire-citerne pour produits pétroliers”.
4 The portion of item 251 of Schedule 1.1 to the English version of the Regulations in the column under the heading “Type” is amended by replacing “Other” with “Oil Tanker”.
| Item | IMO number | Vessel name | Type | Build date |
|---|---|---|---|---|
| 311 | 9242223 | Adonia | Oil Tanker | 2003 |
| 312 | 9842190 | Akademik Gubkin | Oil Tanker | 2023 |
| 313 | 9385142 | Almond | Chemical/Products Tanker | 2009 |
| 314 | 9257993 | Amell | Oil Tanker | 2003 |
| 315 | 9381744 | Antila | Oil Tanker | 2008 |
| 316 | 9280885 | Apus | Oil Tanker | 2004 |
| 317 | 9299745 | Apus | Oil Tanker | 2006 |
| 318 | 9299769 | Aquatica | Oil Tanker | 2005 |
| 319 | 9281152 | Aquila II | Oil Tanker | 2004 |
| 320 | 9397547 | Ariadne | Chemical/Products Tanker | 2008 |
| 321 | 9163764 | Arno Babajanyan | Chemical/Products Tanker | 1999 |
| 322 | 9273387 | Astra | Chemical/Products Tanker | 2003 |
| 323 | 9381732 | Auga | Oil Tanker | 2008 |
| 324 | 9233765 | Aulis | Oil Tanker | 2003 |
| 325 | 9164512 | Avior | Oil Products Tanker | 1999 |
| 326 | 9322839 | Avril | Oil Tanker | 2006 |
| 327 | 9308821 | Berra | Oil Tanker | 2005 |
| 328 | 9323338 | Bettle | Chemical/Products Tanker | 2006 |
| 329 | 9495832 | Blacksea Eagle | Oil Products Tanker | 2008 |
| 330 | 9411331 | Canara | Oil Tanker | 2009 |
| 331 | 9299680 | Cangjie | Oil Tanker | 2005 |
| 332 | 9380673 | Centurion | Oil Tanker | 2008 |
| 333 | 9418482 | Cetus | Oil Tanker | 2013 |
| 334 | 9171175 | Cilicia | Oil Products Tanker | 2000 |
| 335 | 9589750 | Danshui | Oil Tanker | 2011 |
| 336 | 9194983 | Deliver | Oil Tanker | 2006 |
| 337 | 9253894 | Destamar | Oil Tanker | 2002 |
| 338 | 9299903 | Deyna | Oil Tanker | 2005 |
| 339 | 9283241 | Dignity | Oil Tanker | 2004 |
| 340 | 9683726 | Dmitry Pokrovsky | Oil Products Tanker | 2014 |
| 341 | 9383950 | Eminent | Oil Tanker | 2009 |
| 342 | 9079169 | Enisey | Bulk carrier | 1995 |
| 343 | 9308065 | Eventin | Oil Tanker | 2008 |
| 344 | 9283306 | Fina A | Oil Tanker | 2004 |
| 345 | 9238052 | Freya | Oil Tanker | 2002 |
| 346 | 9288851 | Grinch | Oil Tanker | 2004 |
| 347 | 9419448 | Heng Tai | Oil Tanker | 2009 |
| 348 | 9249087 | Hs Glory | Oil Tanker | 2005 |
| 349 | 9312872 | HuiHai Atlantic | Oil Tanker | 2007 |
| 350 | 9256858 | Inda | Oil Tanker | 2003 |
| 351 | 9337133 | Ivy | Oil Tanker | 2007 |
| 352 | 9301392 | Kapitan Kostichev | Oil Tanker | 2005 |
| 353 | 9306782 | Kareliya | Oil Tanker | 2008 |
| 354 | 9327413 | Karol | Chemical/Products Tanker | 2006 |
| 355 | 9258002 | Kazan | Oil Tanker | 2003 |
| 356 | 9412995 | Kruger | Oil Tanker | 2009 |
| 357 | 9339313 | Ladoga | Oil Tanker | 2007 |
| 358 | 9683740 | Lady Leila | Oil Products Tanker | 2014 |
| 359 | 9683738 | Lady Sevda | Oil Products Tanker | 2014 |
| 360 | 9258521 | Lauren II | Oil Tanker | 2004 |
| 361 | 9259599 | Lauryn | Oil Tanker | 2003 |
| 362 | 9256066 | Ligovsky Prospect | Oil Tanker | 2005 |
| 363 | 9339301 | Lipetsk | Oil Tanker | 2006 |
| 364 | 9256078 | Liteyny Prospect | Oil Tanker | 2003 |
| 365 | 9392822 | Lotus | Oil Tanker | 2008 |
| 366 | 9314088 | Lyra | Oil Tanker | 2004 |
| 367 | 9289477 | M Sophia | Oil Tanker | 2004 |
| 368 | 9314105 | Makalu | Oil Tanker | 2005 |
| 369 | 9378632 | Malak | Oil Tanker | 2009 |
| 370 | 9198783 | Maria | Oil Tanker | 2010 |
| 371 | 9187227 | Meru | Oil Tanker | 2000 |
| 372 | 9314818 | Miley | Chemical/Products Tanker | 2006 |
| 373 | 9257137 | Min Hang | Oil Tanker | 2003 |
| 374 | 9233741 | Mitzel | Oil Tanker | 2003 |
| 375 | 9934498 | Nan Feng Zhi Xing | Heavy Load Carrier | 2022 |
| 376 | 9224283 | Neer 1 | Oil Tanker | 2002 |
| 377 | 9256054 | Nevskiy Prospect | Oil Tanker | 2003 |
| 378 | 9266853 | New Power | Oil Tanker | 2004 |
| 379 | 9297357 | Novator | Oil Tanker | 2006 |
| 380 | 9255270 | Np Dikson | Chemical/Products Tanker | 2004 |
| 381 | 9183831 | Np Dudinka | Chemical/Products Tanker | 2000 |
| 382 | 9284594 | Ocean River | Oil Tanker | 2004 |
| 383 | 9268112 | Olia | Oil Tanker | 2003 |
| 384 | 9299719 | Otla | Oil Tanker | 2006 |
| 385 | 9284582 | Panda | Oil Tanker | 2004 |
| 386 | 9378618 | Pioner 1 | Oil Tanker | 2008 |
| 387 | 9350654 | Ruby Cross | Oil Tanker | 2007 |
| 388 | 9524451 | Sabina | Oil Tanker | 2011 |
| 389 | 9322267 | Sahara | Oil Tanker | 2007 |
| 390 | 9530917 | Sakina | Oil Tanker | 2013 |
| 391 | 9300348 | Sanar-10 | Oil Products Tanker | 2004 |
| 392 | 9777670 | Sanar-15 | Oil Products Tanker | 2015 |
| 393 | 9300350 | Sanar-9 | Oil Products Tanker | 2005 |
| 394 | 9301615 | Sara II | Chemical/Products Tanker | 2004 |
| 395 | 9524463 | Satara | Oil Tanker | 2011 |
| 396 | 9296585 | Sensus | Oil Products Tanker | 2005 |
| 397 | 9419137 | Sikar | Oil Tanker | 2010 |
| 398 | 9285847 | Sirius 1 | Oil Tanker | 2005 |
| 399 | 9274446 | Sorion | Oil Tanker | 2004 |
| 400 | 9315446 | Spring | Oil Tanker | 2005 |
| 401 | 9259197 | Thalia III | Oil Tanker | 2003 |
| 402 | 9388754 | Trader | Oil Tanker | 2008 |
| 403 | 9247780 | Turaco | Oil Tanker | 2003 |
| 404 | 9621601 | Vasily Lanovoy | Chemical/Products Tanker | 2016 |
| 405 | 9832547 | Velmar | Oil Tanker | 2018 |
| 406 | 9233349 | Vesna | Oil Tanker | 2000 |
| 407 | 9271327 | View | Oil Tanker | 2003 |
| 408 | 9832559 | Virat | Oil Tanker | 2018 |
| 409 | 9255244 | White Condor I | Oil Products Tanker | 2003 |
| 410 | 9231212 | Xanthos Eos | Oil Tanker | 2002 |
Application Before Publication
6 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
7 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
Russia continues its war against Ukraine, blatantly violating international law and the sovereignty and territorial integrity of Ukraine. In addition to its military operations, Russia applies its hybrid (military and non-military) strategies against Ukraine and the international community, including through cyber operations. Russia continues to finance its war and military industrial base, including artificial intelligence, through energy revenues coming from sanctions evasion, enablers and profiteers in third countries. These actors directly support the Kremlin in moving funds in and out of Russia to pay for arms and other war-related material, and via the use of a shadow fleet (i.e. a network of vessels and various supporting entities around the world) involved in the movement of petroleum products, liquefied natural gas (LNG), arms and other items for the benefit of Russia. LNG exports and related revenues remain a critical source of funding for Russia’s military-industrial complex.
To discourage these behaviours and practices, the Government of Canada is imposing additional economic measures on those responsible for the above actions and practices.
Background
On February 24, 2022, Russia initiated an unprovoked full-scale military invasion of Ukraine 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.
As of August 2025, the UN Human Rights Monitoring Mission in Ukraine has confirmed that at least 13 883 civilians have been killed and over 35 548 have been injured since February 24, 2022. Despite extensive sanctions, Russia has adapted by leveraging cyber actors, entities supporting its military industrial base, shadow fleet vessels and financial intermediaries to sustain its war effort.
Russia has continued to be able to move funds out of the country to pay for arms and related material, and to move funds into the country as payment for exports of energy products. This has, in part, been accomplished through the use of banks in intermediary jurisdictions, also known as Foreign Financial Institutions (FFIs). Several countries, including Canada, have taken action against at least one FFI for intentionally facilitating cross-border payments and continue to take measures to restrict the role of Russian banks as intermediaries.
Oil and gas revenue has traditionally constituted a significant percentage of Russia’s total government revenue. Although economic measures taken by Canada and its partners, including G7 members, have reduced the revenues available to Russia to fund the ongoing war, oil and gas revenues continue to account for roughly 30% of all Russian government revenues.
To evade and circumvent sanctions, especially those on its oil and gas exports, Russia has increasingly made use of a shadow fleet to transport sanctioned goods and commodities. These vessels often intentionally disable or manipulate their automatic identification systems (AIS); have substandard maintenance; frequently change ownership in a covert manner; have inadequate insurance coverage; and engage in dangerous ship-to-ship transfers, mislabelling or blending the cargoes for re-export, often in free trade zone ports, to avoid foreign jurisdictions.
The International Maritime Organization (IMO) highlights several indicators of possible shadow fleet activity.
- AIS tampering — disabling or manipulating tracking systems to hide movements.
- Flags of convenience — frequent reflagging with states lacking enforcement.
- Unrecognized insurance — operating without standard marine insurance.
- Poor vessel condition — aging ships failing safety and environmental standards.
- Hidden ownership — use of shell companies to obscure true ownership;
- Suspicious routes — ship-to-ship transfers in poorly monitored areas.
- Port avoidance — skipping ports with strict inspections or failing them.
International response
Canada’s partners, including G7 and European Union (EU) members, have continued to impose coordinated and aligned sanctions measures targeting Russia’s energy sector, financial networks and maritime logistics. International efforts also focus on countering cyber threats and sanction circumvention through shadow fleets.
A group of countries directly supporting Ukraine, including but not limited to the G7 and European countries, is working to support Ukraine across several 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, providing military assistance, ensuring accountability and fostering socio-economic recovery and reconstruction.
Key international partners have continued to update their sanctions regimes to increase pressure on Russia through coordinated efforts towards these ends.
The 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.
Canada’s response
Canada unequivocally condemns Russia’s unjustified and egregious actions. Following Russia’s unjustified occupation and attempted 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. 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). In addition, Canada has put in place a wide range of other economic restrictions under the Russia Regulations. These include a prohibition on certain types of ships entering or passing through Canada. In February 2025, to support enforcement of this general prohibition, Schedule 1.1 was established to list ships specifically identified by their IMO number.
Since 2014, in coordination with its partners, Canada has imposed sanctions on more than 3 300 individuals and entities in Russia, Belarus, Ukraine and Moldova, and has listed over 300 vessels. 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) and transport sectors. Canada is part of 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.
Given the importance of oil and gas revenue to Russia’s economy and its war effort, Canada and G7 partners have sought to limit Russian access to revenue from the energy sector through various measures. Canada is part of the Oil Price Cap Coalition. 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.
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. In February 2025, Canada amended the Russia Regulations by adding a new schedule containing a list of ships that are believed to be transporting or have transported property or goods on behalf of or for the benefit of Russia or a person in Russia. In June 2025, the Russia Regulations were further amended to include an additional prohibition on the provision of financial services or any other services to any person outside Canada who is not Canadian, where the services relate to a ship listed in Schedule 1.1 of the Russia Regulations.
In coordination with like-minded partners, Canada has recently identified several individuals, entities and vessels that are engaged in activities, including cyber operations, linked to Russia’s military base, its hybrid strategy against Ukraine and its shadow fleet operations.
Objective
- Constrain Russia’s ability to fund its conventional military and hybrid capabilities used in its war of aggression against Ukraine, to support Ukraine and reinforce Canada’s commitment to international security and the rule of law.
- Further increase the economic costs to Russia for its war against Ukraine by targeting its energy revenues and financial enablers.
Description
The amendments
- add 13 individuals, including a senior executive of a Russian LNG firm enabling Kremlin revenue and military funding, cyber infrastructure enablers using crypto channels, senior Russian security officials instrumental in Moscow’s hybrid strategy, an essential component of its broader military campaign against Ukraine, and malign influence operators;
- add 11 entities, including financial institutions enabling sanctions evasion, companies linked to Russian energy trading networks, LNG exports, drone developers supporting Russia’s military-industrial base and Russia’s military intelligence units responsible for cyber operations; and
- add 100 vessels to Schedule 1.1 for involvement in shadow fleet activities facilitating the transport of oil, LNG, arms and other sanctioned goods.
The ships listed have been involved in the transport of goods, such as crude oil, LNG, or arms and related material, on behalf of or for the benefit of Russia or a person in Russia.
These amendments further align Canada’s measures with G7 and like-minded partners by expanding sanctions on the energy, financial and maritime sectors to further isolate Russia economically and strategically, including targeting enablers and profiteers in Russian and third-country financial sectors.
Any person 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 Russia Regulations. Listed individuals are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act (IRPA).
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. Information on the delisting application process is available on Global Affairs Canada’s website.
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.
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.
Indigenous engagement, consultation and modern treaty obligations
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 amendments in relation to modern treaties in effect, and no modern treaty obligations were identified.
Instrument choice
The imposition of sanctions against foreign states and non-state actors is a key tool for the international community to support peace and security and enforce international norms and laws. The Parliament of Canada has enacted legislation authorizing the imposition of sanctions through the United Nations Act, the SEMA, and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).
Canada has established a rigorous due diligence process to consider and evaluate possible cases that may warrant the use of sanctions. Given the elements in the amendments, 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
These amendments to the Russia Regulations will strengthen existing economic measures against Russia, 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 these sanctions, Canada signals its strong condemnation of Russia’s ongoing behaviour.
The incremental cost to the Government of Canada to administer and enforce these additional prohibitions will be minimal. The Canada Border Services Agency (CBSA), the Royal Canadian Mounted Police (RCMP), Immigration, Refugees and Citizenship Canada (IRCC) and other departments and agencies will incur a small cost to ensure their relevant systems include the persons and vessels 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, entities and ships to their existing monitoring systems, which will also 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 (FINTRAC). Financial institutions also have other legal obligations with respect to the monitoring and reporting of relevant property ownership, export and import of goods and other activities in connection with sanctioned individuals and entities.
Sanctions targeting specific persons have less impact on Canadian businesses than traditional broad-based economic sanctions. Based on an initial assessment of available open-source information and consultations within the Government of Canada, it is believed that the individuals and entities listed in the amendments have limited linkages with Canada and, therefore, do not have business dealings that are significant to the Canadian economy. It is therefore anticipated that there will be no significant impacts on Canadians or Canadian businesses as a result of these amendments.
The amendments related to the listing of vessels are also not expected to result in incremental impacts on Canada. Since 2022, the Russia Regulations have banned certain ships from docking in or passing through Canada. This applies to all 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. While the amendments do not introduce new prohibitions, listing the 100 identified vessels will facilitate the enforcement of the general prohibition on docking and passage in Canada. Without the names of the vessels in 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.
In relation to the prohibition on the provision of services to vessels, all Canadian companies providing services related to vessels, such as insurance, technical services or ship supply services, will be required to screen against Schedule 1.1, to ensure that they are not providing a service in relation to a listed vessel. There is no data available to ascertain if any Canadian businesses are currently providing services in relation to listed vessels. However, Global Affairs Canada has concluded that it is highly unlikely that any Canadian businesses currently provide such services, as there is no record of these vessels entering Canada, and none of the vessels are owned, managed, operated or insured by Canadian companies.
Small business lens
Analysis under the small business lens concludes that the amendments will not impact Canadian small businesses, as it is highly unlikely that Canadian businesses have dealings with the individuals, entities and/or vessels included in the amendments.
Canadian businesses may seek permits under the Special Economic Measures Permit Authorization Order to allow them to perform a specified activity with a listed person. Those permits are granted on an exceptional basis. However, Global Affairs Canada does not anticipate any applications resulting from listing these persons or ships, as the department’s assessment has not identified business dealings that are significant to Canada’s economy.
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 individuals, entities and ships 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 Special Economic Measures Permit Authorization Order 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 and its infringement of Ukraine’s sovereignty and territorial integrity include Australia, the European Union, Japan, New Zealand, Switzerland, the United Kingdom and the United States. The persons and vessels listed in the amendments have been subject to sanctions by like-minded nations. These measures also align with Canada’s commitment following the signature of the United Kingdom-led call to action on the shadow fleet. In addition, the United States, the European Union and the United Kingdom all prohibit wider categories of activity, including services in relation to listed ships.
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
A gender-based analysis plus (GBA+) concluded that the amendments are unlikely to result in differential impacts on the basis of identity factors, including but not limited to gender, race, ethnicity, sexual orientation and religion.
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. Insofar as sanctions limit Russia’s ability to wage war, individuals and groups vulnerable to gender-based discrimination 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 IRPA, 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 persons in Canada and Canadians outside of Canada to comply with the amendments.
The Trade Commissioner Service at Global Affairs Canada, both abroad and in Canada, continues to assist clients in understanding Canadian sanctions regulations, notably the impact of these 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 engagement with businesses, universities and provincial and territorial governments, to enhance national awareness of and compliance with Canadian sanctions.
The prohibitions on ships entering or passing through Canada are enforced by a multi-departmental process involving, among others, Transport Canada, the Canadian Coast Guard, the CBSA and the RCMP. These partners were consulted in the development of the amendments.
Under the SEMA, both RCMP and CBSA officers have the power to enforce sanctions measures 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
Email: sanctions@international.gc.ca
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085