Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2026-122

Canada Gazette, Part II, Volume 160, Number 13

Registration
SOR/2026-122 June 12, 2026

SPECIAL ECONOMIC MEASURES ACT

P.C. 2026-596 June 12, 2026

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1 Subsections 8(3) and (4) to the Special Economic Measures (Russia) Regulations footnote 1 are repealed.

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

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

4 The portion of items 12 and 13 of Schedule 1.1 in the French version of the Regulations in the column under the heading “Type” is replaced by the following:
Article Type
12 Cargo roulier
13 Cargo roulier
5 Schedule 1.1 to the Regulations is amended by adding the following in numerical order:
Item IMO number Vessel name Type Build date
611 9328170 Aether Crude Oil Tanker 2007
612 9904546 Aleksey Kosygin LNG Tanker 2025
613 6703769 Alireza 1 General Cargo 1965
614 8711306 Andrey Osipov General Cargo 1994
615 9417464 Anika Crude Oil Tanker 2009
616 9190286 Aquilon General Cargo 1999
617 9228980 Arctica-1 General Cargo 2001
618 9243801 Arctica-2 General Cargo 2002
619 8714695 Arkadiy Chernyshev General Cargo 1988
620 9166314 Astoria Chemical/Products Tanker 1999
621 9337418 Atmos Crude Oil Tanker 2007
622 9278600 Barents General Cargo 2003
623 9267297 Bering General Cargo 2003
624 9439383 Bhilva Crude Oil Tanker 2010
625 9103817 Boris Kustodiev General Cargo 1994
626 9247778 Breez Crude Oil Tanker 2002
627 9343986 Capella MB Oil Products Tanker 2007
628 8318740 Captain Yakubovich General Cargo 1984
629 9252400 Celine Oil Products Tanker 2002
630 9637492 Clean Ocean LNG Tanker 2014
631 9637507 Clean Planet LNG Tanker 2014
632 9655456 Clean Vision LNG Tanker 2016
633 9274616 Deimos Crude oil tanker 2004
634 9888182 Dmitry Mendeleev Bunkering Tanker (LNG) 2021
635 9298595 Dorry Chemical/Products Tanker 2005
636 9297541 Dove Crude Oil Tanker 2006
637 9290385 Elbus Crude Oil Tanker 2005
638 9620633 Finval Bulk Carrier 2012
639 9258478 Foya Crude Oil Tanker 2004
640 9742120 Gennadiy Nevelskoy Offshore Supply Vessel 2017
641 9252967 Gracep Crude Oil Tanker 2003
642 9237412 Hanson Crude Oil Tanker 2004
643 9408554 He Bo Crude Oil Tanker 2009
644 9413004 Horae Crude Oil Tanker 2009
645 9270555 Integrity Racer Crude Oil Tanker 2003
646 9253909 James II Crude Oil Tanker 2002
647 9430272 Jin Hui Chemical/Products Tanker 2009
648 9265873 Kamelot Oil Products Tanker 2004
649 9621558 Karakuz Oil Products Tanker 2013
650 9282041 Kaviz Crude Oil Tanker 2004
651 8606616 Kompozitor Rakhmaninov Ro-Ro Cargo 1986
652 9142588 Kunashir General Cargo 1998
653 9380570 Kurdos III Chemical/Products Tanker 2008
654 9306809 Layla Chemical/Products Tanker 2006
655 9673202 Legenda Bulk Carrier 2014
656 9408542 Ling Hong Crude Oil Tanker 2008
657 9217979 Lotta Floating Storage and Offloading Unit (FSO), oil 2001
658 9299135 Mandala Chemical/Products Tanker 2006
659 9296377 Marjorie Crude Oil Tanker 2006
660 9305556 Marven Crude Oil Tanker 2005
661 9550137 Matros Koshka Bulk Carrier 2009
662 9573816 Matros Pozynich Bulk Carrier 2010
663 9081370 Mikhail Britnev General Cargo 1995
664 9515539 Mikhail Nenashev Bulk Carrier 2009
665 9433286 Mys Flora General Cargo 2009
666 9243825 Mys Shmidta General Cargo 2003
667 9366110 Mys Zhelaniya General Cargo 2008
668 9233777 Ocean II Crude Oil Tanker 2003
669 8926913 Omskiy-119 General Cargo 1980
670 9390587 Oneiroi Crude Oil Tanker 2008
671 9131357 Orion Crude Oil Tanker 1997
672 9321718 Orvi Crude Oil Tanker 2006
673 9260067 Ostria Chemical/Products Tanker 2003
674 9190274 Oxin General Cargo 1999
675 9159921 Patria Ro-Ro Cargo 1999
676 9481934 Port Olya-4 General Cargo 2014
677 9286073 Rcelebra Crude Oil Tanker 2005
678 9645011 Sanar-18 Oil Products Tanker 2012
679 8862935 Sanrayz Oil Products Tanker 1986
680 9383869 Saraswati Crude Oil Tanker 2008
681 9358034 Sasco Aldan General Cargo 2007
682 9242986 Sasco Angara Container Ship 2001
683 9255402 Sasco Aniva Container Ship 2002
684 9246140 Sasco Avacha Container Ship 2001
685 9037123 SC Cutta Oil Products Tanker 2001
686 9335678 SCF Endeavour Offshore Supply Vessel 2006
687 9335680 SCF Endurance Offshore Supply Vessel 2006
688 9335692 SCF Enterprise Offshore Supply Vessel 2006
689 9307724 SCF Sakhalin Offshore Supply Vessel 2006
690 9333785 Seadar Crude Oil Tanker 2007
691 9256028 Seginus Oil Products Tanker 2003
692 8714657 Selenga General Cargo 1988
693 9637961 Sergey Terskov Crude Oil Tanker 2016
694 9779941 Shusha Crude Oil Tanker 2017
695 9735335 Sig Chemical/Products Tanker 2014
696 9291262 Silvar Crude Oil Tanker 2005
697 9323364 Silver Ice Chemical/Products Tanker 2007
698 9179385 Simushir General Cargo 1998
699 9263693 Sino Star Chemical/Products Tanker 2003
700 9230971 Skadi Crude Oil Tanker 2001
701 9268710 Sparta Ro-Ro Cargo 2003
702 9690212 Stalingrad Chemical/Products Tanker 2014
703 9621596 Stanislav Govorukhin Chemical/Products Tanker 2016
704 9290397 Stormbringer Crude Oil Tanker 2005
705 9282481 Tagor Crude Oil Tanker 2005
706 9408695 Tassos Crude Oil Tanker 2009
707 9164718 Thoth Chemical/Products Tanker 1999
708 9389083 Tiger 6 Crude Oil Tanker 2009
708 9274082 TM Hai Ha 568 Chemical/Products Tanker 2004
710 9298492 Toa Payoh Chemical/Products Tanker 2005
711 9676230 Truvor Chemical/Products Tanker 2013
712 9308077 Tyche 1 Crude Oil Tanker 2006
713 9196620 Umba Floating Storage and Offloading Unit (FSO) 2001
714 9336517 Uriel Oil Products Tanker 2007
715 8422670 Vafa General Cargo 1984
716 8422682 Vafa-1 General Cargo 1984
717 8724779 Vanino Oil Products Tanker 1986
718 9451642 Vengery Offshore Supply Vessel 2010
719 9379301 Versa Crude Oil Tanker 2008
720 9212008 Victoria Crude Oil Tanker 2000
721 9613549 Vitus Bering Offshore Supply Vessel 2012
722 9422988 Volans Crude Oil Tanker 2009
723 8867129 Volgoneft-160 Oil Products Tanker 1981
724 8231057 Volgoneft-251 Oil Products Tanker 1975
725 9337327 West Horizon Chemical/Products Tanker 2006
726 9720263 Zafar Bulk Carrier 2015
727 9498171 Zagatala Oil Products Tanker 2008
728 9715270 Zaid Bulk Carrier 2015
729 8951413 Zakamsk General Cargo 1966
730 9211896 Zal Pars 3 Oil Products Tanker 1999
731 9118355 Zeya Container Ship 1995

6 The heading of Schedule 4 to the Regulations is replaced by the following:

Goods — Export, Sell, Supply or Ship

7 The heading of Schedule 5 to the Regulations is replaced by the following:

Goods — Import, Purchase or Acquire

8 The heading of Schedule 5.01 to the Regulations is replaced by the following:

Coal — Import, Purchase or Acquire

9 The heading of Schedule 5.02 to the Regulations is replaced by the following:

Jet Fuel and Additives — Export, Sell, Supply or Ship

10 The heading of Schedule 5.1 to the Regulations is replaced by the following:

Goods and Technologies — Export, Sell, Supply or Ship

11 The heading of Part 1 of Schedule 6 to the Regulations is replaced by the following:

Luxury Goods — Export, Sell, Supply or Ship

12 The portion of items 251 to 253 of Part 1 of Schedule 6 in the English version of the Regulations in column 1 is replaced by the following:
Item

Column 1

Goods
251 Collections or collectors’ pieces of zoological, botanical, mineralogical, anatomical, paleontological interest: human specimens and parts thereof
252 Collections or collectors’ pieces of zoological, botanical, mineralogical, anatomical, paleontological interest: extinct or endangered species and parts thereof
253 Collections or collectors’ pieces of zoological, botanical, mineralogical, anatomical, paleontological interest: other than human specimens or extinct or endangered species

13 The heading of Part 2 of Schedule 6 to the Regulations is replaced by the following:

Luxury Goods — Import, Purchase or Acquire

14 The portion of items 1 to 6 of Part 2 of Schedule 6 to the English version of the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
1 0301
2 0302
3 0303
4 0304
5 0305
6 0306

15 The heading of Schedule 7 to the Regulations is replaced by the following:

Industrial Goods — Export, Sell, Supply or Ship

16 The portion of item 145 of Schedule 7 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
145 36
17 The portion of item 171 of Schedule 7 to the English version of the Regulations in column 1 is replaced by the following:
Item

Column1

Goods
171 Prepared binders for foundry moulds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included. - Sorbitol other than that of subheading 2905.44 (except where it contains 2% or less by weight of D-mannitol, calculated on the D-glucitol content)

18 Item 197 of Schedule 7 to the Regulations is repealed.

19 The portion of item 354 of Schedule 7 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
354 72
20 The portion of item 400 of Schedule 7 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
400 76
21 The portion of item 592 of Schedule 7 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
592 85
22 The portion of item 624 of Schedule 7 to the Regulations in column 1 is replaced by the following:
Item

Column 1

Goods
624 Parts and accessories of vehicles of headings 87.11 to 87.13. - Of motorcycles (including mopeds)
23 The portion of item 628 of Schedule 7 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
628 89

24 The heading of Schedule 9 to the Regulations is replaced by the following:

Gold — Import, Purchase or Acquire

25 The heading of Part 1 of Schedule 10.1 to the Regulations is replaced by the following:

Chemicals — Export, Sell, Supply or Ship

26 The heading of Part 2 of Schedule 10.1 to the Regulations is replaced by the following:

Related Goods — Export, Sell, Supply or Ship

27 The heading of Part 3 of Schedule 10.1 to the Regulations is replaced by the following:

Related Goods (Parts and Consumables) — Export, Sell, Supply or Ship

28 The heading of Part 1 of Schedule 11 to the Regulations is replaced by the following:

Metals (Iron, Steel and Aluminum) — Import, Purchase or Acquire

29 The portion of item 1 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
1 72
30 The portion of item 12 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
12 7311
31 The portion of item 16 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
16 7315
32 The portion of item 19 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
19 7318
33 The portion of items 24 and 25 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
24 7323
25 7324
34 The portion of items 27 to 30 of Part 1 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
27 7326
28 74
29 75
30 76

35 The heading of Part 2 of Schedule 11 to the Regulations is replaced by the following:

Other Metals — Import, Purchase or Acquire

36 The portion of items 1 to 3 of Part 2 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
1 78
2 79
3 80
37 The portion of items 15 and 16 of Part 2 of Schedule 11 to the Regulations in column 2 is replaced by the following:
Item

Column 2

Harmonized Commodity Description and Coding System code
15 82
16 83

38 The heading of Part 1 of Schedule 12 to the Regulations is replaced by the following:

Diamonds from Any Country — Import, Purchase or Acquire

39 The heading of Part 2 of Schedule 12 to the Regulations is replaced by the following:

Diamonds from Russia — Import, Purchase or Acquire

40 The heading of Part 1 of Schedule 13 to the Regulations is replaced by the following:

Revenue-Generating Goods — Import, Purchase or Acquire

41 The heading of Part 2 of Schedule 13 to the Regulations is replaced by the following:

Revenue-Generating Goods — Import, Purchase or Acquire

Application Before Publication

42 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

43 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’s war of aggression against Ukraine violates international law and has upended the European security architecture. While international sanctions have been effective in hampering Russia’s war efforts, maintaining pressure requires Canada to continuously adapt its sanctions regime.

Since its full-scale invasion in 2022, Russia has continued to exploit regulatory gaps, third-country intermediaries, and various dual-use civilian industries. Russia continues to sustain its war of aggression against Ukraine by restructuring its revenue streams, adapting sanctions-evasion mechanisms, and expanding military production capacity.

Canada aims to further increase the economic costs to Russia for its war against Ukraine by targeting its energy revenues, including its shadow fleet vessels and their enablers. Canada also aims to degrade Russia’s conventional military and hybrid military capabilities by targeting its defence-industrial base and by limiting the ability of certain financial institutions to enable sanctions circumvention for the benefit of Russia.

In addition, Global Affairs Canada (GAC) continuously reviews its sanctions regime to ensure that regulatory provisions remain clear, coherent, and administrable in light of evolving operational realities. Through this review, GAC identified certain aspects of the Special Economic Measures (Russia) Regulations (the Russia Regulations) that would benefit from correction, clarification, or repeal in order to better support rigorous and defensible decision-making.

Among these changes is the repeal of item 197 (sanctioned in June 2025), which covers a product used for the transport of animal semen, which is not a sanctioned good. The repeal of this item will allow the continued use of it for the transportation of an unsanctioned good that is used for food production and is related to human food security.

A further change includes the repeal of subsections 8(3), which removes the 90-day time limit for a ministerial decision on an application requesting the removal of a “person” (defined in the Special Economic Measures Act [SEMA] as “an individual or an entity”) or a vessel from a schedule of the Russia Regulations (delisting application), and 8(4), which removes the requirement for the Minister of Foreign Affairs (Minister) to notify the applicant without delay of a decision taken. Removal of the prescribed time limits is intended to allow for reasonable time to conduct due diligence, careful examination of evidence, consultations, and analysis on delisting applications received under subsection 8(1) of the Russia Regulations.

Background

Revenue-generating strategic sectors, particularly energy and nuclear services, remain foundational to Russia’s economy. Russia continues to export energy to generate revenue by relying on sanctions-evasion practices that include the use of opaque shipping arrangements, non-transparent ownership structures, and insurance mechanisms operating outside established international oversight. These practices are often facilitated through intermediaries in third countries rather than through legitimate, fully compliant commercial shipping markets. Russia’s state-owned nuclear sector also contributes to government revenues but has remained largely insulated from sanctions due to global dependencies on Russian fuel, technology, and long-term contracts.

Logistics and sanctions-evasion networks underpin these revenue flows. Russia has expanded its use of an aging and poorly regulated maritime “shadow fleet,” comprising vessels that frequently change flags, conceal beneficial ownership, disable tracking systems, and rely on alternative or inadequately backed insurance, to circumvent price caps and transparency requirements. In parallel, cryptocurrency-based financial channels and alternative payment mechanisms increasingly facilitate cross-border transactions and asset concealment.

Russian sanctions evasion and illicit financial flows are also a main source of funding for Russia’s defence-industrial base, particularly drone and unmanned aerial systems (UAS) production — a critical pillar of its war effort. Russia has rapidly scaled up drone manufacturing through a partially civilian-branded ecosystem closely integrated with military demand to enable sustained battlefield operations in Ukraine.

Together, these interconnected revenue streams, logistics networks, financial channels, and industrial capabilities continue to enable Russia’s war effort. Strengthening and aligning sanctions across these areas remains critical to disrupting Russia’s capacity to finance and sustain its aggression.

On June 13, 2025, Canada prohibited, under item 197 of Schedule 7 of the Russia Regulations, the export, sale, supply or shipment for the conveyance or packing of goods, certain plastic containers (bottles, flasks and similar articles), generally used for the storing and shipment of animal semen. While these containers are sanctioned, the animal semen itself is not sanctioned. Canada is the second-largest global exporter of animal semen. Repealing item 197 ensures that exports of animal semen are not unintentionally hindered by a restriction on the containers needed for their transport. This repeal is intended to align with Canada’s policy of not adversely affecting global food security.

Under subsection 8(1) of the Russia Regulations, a person may apply to the Minister of Foreign Affairs requesting the removal of their name, or of a ship they own, operate or manage, from Canada’s sanctions list. On receipt of the application, the Minister must decide, in accordance with subsection 8(2), whether there are reasonable grounds to recommend the removal to the Governor in Council. Subsection 8(3) requires the Minister to decide on the application within 90 days after the day on which the application is received. Under subsection 8(4), the Minister must give notice without delay to the applicant of the decision taken.

Since the start of Russia’s full-scale invasion of Ukraine in 2022, there has been a significant increase in the number of sanctions adopted under the Russia Regulations. Consequently, there has been an increase in the volume and complexity of applications from persons requesting removal from Canada’s sanctions list under subsection 8(1) of these regulations. In practice, the prescribed 90-day timeline has proven insufficient to allow for careful examination of evidence, consultations, and analysis required to ensure delisting applications are reviewed with the appropriate due diligence, particularly where applications raise complex factual, legal, or policy considerations, and GAC must seek additional information either from the applicants or conduct its own investigation to verify the information provided in the application. The repeal of subsection 8(3), and the related notice period in subsection 8(4), are critical to ensuring a thorough and comprehensive assessment of delisting applications and supporting documentation provided by the applicants. The repeal of subsections 8(3) and 8(4) would also align the Russia Regulations with most other Regulations under the SEMA, which do not include these provisions.

International response

Canada and its partners have maintained coordinated pressure on Russia through comprehensive sanctions targeting its energy sector, financial networks, maritime logistics, and defence-industrial base. These measures aim to degrade Russia’s war machine and financing capabilities.

A broad coalition of countries supporting Ukraine continues to assist across multiple areas: energy security, nuclear safety, food security, humanitarian aid, combating Russian disinformation, imposing sanctions and economic measures, asset seizure and forfeiture, military assistance, accountability initiatives, and socio-economic recovery and reconstruction. Sanctions regimes are regularly updated to increase pressure and close loopholes exploited by Russia and third-country enablers.

Canada’s response

Canada, alongside like-minded partners, has imposed extensive sanctions under the Special Economic Measures Act (SEMA) in response to Russia’s violations of Ukraine’s sovereignty. Canada has sanctioned more than 3 400 individuals and entities across Russia, Belarus, Ukraine, and Moldova since 2014. Restrictions target financial, trade, and transport sectors, including Russian networks operating through third countries. Furthermore, Canada has acted against foreign financial institutions for intentionally facilitating cross-border payments in sanction circumvention efforts and continues to restrict the role of Russian banks as intermediaries.

Under the Russia Regulations, Canada prohibits the import of Russian crude oil, refined petroleum products, and gaseous hydrocarbons, and prohibits exports of goods and services related to oil exploration and production in Russia. Canada also broadly prohibits services supporting Russia’s energy, manufacturing, and transportation sectors.

To strengthen enforcement, Canada has barred Russian-linked vessels from Canadian waters since 2022, and prohibited financial or other services related to these vessels. Since these amendments were introduced, Canada has added over 600 vessels to this schedule.

Under Canada’s G7 presidency in 2025, participating G7 members launched a Shadow Fleet Task Force with members of the Nordic-Baltic 8 (Denmark, Estonia, Finland, Iceland, Latvia, Lithuania, Norway, and Sweden) to enhance monitoring, detection and coordination to disrupt and deter the global shadow fleet engaged in illegal, unsafe, and environmentally hazardous activities. Russia is increasingly reliant on its shadow fleet to circumvent international sanctions on Russian exports.

Objective

Description

The amendments to the Russia Regulations

Any person in Canada or Canadians outside Canada is prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed 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 proposal 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.

Canada has established a rigorous due diligence process to consider and evaluate possible cases that may warrant the use of sanctions, as well as to review its sanctions regime to ensure that regulatory provisions remain clear, coherent, and administrable in light of evolving operational realities and requests for clarifications from Canadian stakeholders. Given the elements proposed 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 proposed 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 persons from contributing, directly or indirectly, to Russia’s war efforts. The amendments will also further enhance clarity and consistency under the Russia Regulations and with the SEMA and directly benefit Canadians and Canadian businesses by facilitating the interpretation and application of existing restrictions and prohibitions.

The incremental cost to the Government of Canada to administer and enforce the additional prohibitions will be minimal. The Canada Border Services Agency (CBSA), the Royal Canadian Mounted Police (RCMP), and Immigration, Refugees and Citizenship Canada (IRCC) will incur a small cost to ensure their relevant systems include, as applicable, the persons, the vessels, and the updated list of items included in these amendments.

Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed persons and vessels to their existing monitoring systems, resulting 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 monitoring and reporting of relevant property ownership, export and import of goods and other activities in connection with sanctioned persons.

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 most of the persons listed in the amendments have limited linkages with Canada and do not have business dealings that are significant to the Canadian economy.

The amendments related to the listing of vessels are not expected to result in incremental impacts on Canada. Since 2022, the Russia Regulations have banned certain vessels from docking in or passing through Canada. This applies to all vessels 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 identified vessels will facilitate the enforcement of the general prohibition on docking and passage in Canada. Without the names of the vessels in Schedule 1.1, enforcement authorities must determine on a case-by-case basis whether a vessel is subject to the general prohibition. Schedule 1.1 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.

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 because there is no record of these vessels entering Canada, and none of the vessels are owned, managed, operated or insured by Canadian companies.

The repeal of item 197 from Schedule 7 is intended to remove an item used as a container for the purposes of shipping a Canadian agricultural item. The change is expected to be beneficial to a small category of Canadian agricultural exporters, allowing them to continue to export animal semen to Russia using item 197 and therefore help minimize unintended adverse consequences for food security.

The repeal of subsections 8(3) and 8(4) is intended to enable a more thorough, evidence-based review of applications received under subsection 8(1) of the Russia Regulations requesting the removal of a person or a ship from Canada’s sanctions list. This change supports procedural fairness and accountability in the review process. The Minister remains obligated to determine whether there are reasonable grounds to recommend to the Governor in Council the removal of a person or a vessel from the Russia Regulations and to provide notice of the decision to the applicant. The repeal of subsections 8(3) and 8(4) does not alter these substantive requirements; rather, it ensures that decisions are not constrained by timelines that may compromise due diligence or the integrity of the review process.

As a result of these amendments, the review process is expected to remain fair and transparent, as GAC will continue to engage with applicants throughout the process and inform them of decisions in respect of their applications. Finally, the repeal of subsections 8(3) and 8(4) aligns the Russia Regulations with most other Regulations under the SEMA, which do not include these provisions.

Small business lens

Analysis under the small business lens concluded that the amendments listing new persons are unlikely to impact Canadian small businesses, as it is believed that most of the persons listed in the amendments have limited linkages with Canada and do not have business dealings that are significant to the Canadian economy. The amendments listing new persons and vessels will not impose any new compliance or administrative burden on small businesses in Canada. The repeal of item 197 from Schedule 7 is expected to be beneficial to a category of Canadian small businesses in the agricultural sector. The annual average of exports of animal semen to Russia from 2021 to 2024 represents CAD 7,922,074.

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. Global Affairs Canada does not anticipate any applications resulting from listing these persons or vessels because no business dealings significant to Canada’s small businesses have been identified.

Canadian small businesses are subject to the duty to disclose under the Russia Regulations, which represents a direct compliance requirement. However, as the newly listed persons and vessels have no known legitimate linkages with Canadian small businesses, 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, as permits may be granted under the Special Economic Measures Permit Authorization Order on an exceptional basis. Given that the newly listed persons and vessels have no known dealings with Canada, 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. Countries and jurisdictions that have sanctioned persons and vessels related to Russia’s infringement of Ukraine’s sovereignty and territorial integrity as well as Russia’s gross and systematic violations of human rights include Australia, the European Union, Japan, New Zealand, Switzerland, the United Kingdom and the United States.

International obligations

Compliance with Canada’s international commitments was considered in the development of this proposal.

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 plus (GBA+) assessment concluded that the amendments are unlikely to result in differential impacts on the basis of identity factors such as gender, race, ethnicity, sexuality, religion, etc.

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 persons 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.

The repeal of subsections 8(3) and 8(4) will apply to applications received from the date of entry into force and onwards.

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 persons 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, 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 through presentations and other events — including to engage with businesses, universities, and provincial/territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

The prohibitions on vessels entering or passing through Canada are enforced by a multi-departmental process involving Transport Canada, the Canadian Coast Guard, the CBSA, the RCMP and others. 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
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085
Email: sanctions@international.gc.ca