Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2026-172

Canada Gazette, Part II, Volume 160, Number 17

Registration
SOR/2026-172 August 6, 2026

SPECIAL ECONOMIC MEASURES ACT

P.C. 2026-731 August 6, 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

Amendment

1 Part 2 of Schedule 1 to the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in numerical order:

Application Before Publication

2 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.

Coming Into Force

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

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

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 and its partners to continuously adapt their sanctions regimes to mount pressure and counter Russia’s attempts at circumvention.

Background

Russia’s full-scale invasion of Ukraine on February 24, 2022, violated the United Nations (UN) Charter and international law. More than four years later, the war persists, marked by ongoing Russian aggression and atrocities. To sustain the conflict, Russia has restructured its economy around military production and capacity building. This includes developing elaborate methods to source sanctioned goods and military and defence equipment, as well as leveraging its networks and partners to achieve these objectives.

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, including the G7, Australia, the European Union and New Zealand, 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 3 500 individuals and entities across Russia, Belarus, Ukraine and Moldova since 2014. Restrictions target financial, trade, transport and defence-industry sectors, including supporting networks operating in 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 Special Economic Measures (Russia) Regulations (the Russia Regulations), Canada prohibits dealings with a wide range of entities and individuals involved in supporting or enabling Russia’s violation of Ukraine’s sovereignty. These targeted sanctions are continually developed and applied to disrupt Russia’s defence industrial base and sensitive technology sectors that contribute to Russia’s military capacities and capabilities. Canada’s sanctions regime continues to evolve in response to the Russian government’s adaptation to sanctions measures, with a focus on addressing illicit flows of goods and revenues that support the war effort.

Objective

The objective of the amendment is to degrade Russia’s military capabilities used against Ukraine in Russia’s war of aggression.

Description

The amendment 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 individuals and entities (defined in the SEMA as “persons”), unless explicitly authorized by a permit granted on an exceptional basis or an exception in the Russia Regulations.

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, 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 the amendment. Publicizing the name of the listed entity targeted by sanctions could have resulted in asset flight and sanctions evasion prior to the coming into force of the amendment, 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 amendment is likely to give rise to modern treaty obligations. The assessment examined the geographic scope and subject matter of the amendment 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. Given the elements proposed in the amendment, 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 amendment. No other instrument could be considered.

Regulatory analysis

Benefits and costs

This amendment to the Russia Regulations will strengthen existing economic measures against Russia, constrain Russia’s ability to resource its unjustified war in Ukraine, and discourage individuals and entities from contributing, directly or indirectly, to Russia’s war efforts.

The incremental cost to the Government of Canada to administer and enforce this additional prohibition 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 the entity listed through this amendment.

Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed entity to their existing monitoring systems, resulting in a minor compliance cost. As of August 2024, financial institutions must report transactions suspected to be 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 any 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 the entity in question has diminishing links to Canada, as no trade has been reported since September 2025, and all export permits previously issued have expired. According to general domestic export data, Canadian exports to the entity or associated entities represented a total of $3.6 million between 2020 and 2025. According to export control data, six export permits were granted to Canadian businesses to ship goods subject to export controls under the Export Control List to the entity or associated entities since 2020. Based on available permit utilization reports, a total of five shipments were made between 2020 and 2024. No trade, of either export-controlled or non-Export Control List goods, has been reported since September 2025 and the six export permits issued have expired. Based on available information, Global Affairs Canada is not aware of any new permits or permit renewal applications from Canadian businesses.

However, any Canadian exporters that have planned transactions with the listed entity, or that might otherwise have pursued commercial opportunities with the listed entity, will incur adjustment costs and may experience forgone business opportunities and associated costs if they are required to withdraw from negotiations and redirect their exports to other clients. Given the relatively low historical volume of trade with this entity and limited recent activity, these impacts are expected to be low. It is assumed that any impacted Canadian exporters will be able to find alternative buyers.

Small business lens

Analysis under the small business lens concluded that the amendment could affect any Canadian small business that otherwise may have considered dealing in the property of, enter into transactions with, provide services to, transfer property to, or otherwise make goods available to the listed entity.

Canadian small businesses are subject to the duty to disclose under the Russia Regulations, which represents a direct compliance requirement.

One-for-one rule

The one-for-one rule does not apply, as there is no incremental change in administrative burden on businesses. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act. As permits may be granted under the Special Economic Measures Permit Authorization Order on an exceptional basis, it is possible that some businesses may wish to deal with the newly listed entity and will seek permits to conduct specific activities.

Regulatory cooperation and alignment

While the amendment is not related to a work plan or commitment under a formal regulatory cooperation forum, it aligns with actions taken by Canada’s partners. Countries and jurisdictions that have sanctioned individuals, entities 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 amendment.

Effects on the environment

The amendment is unlikely to result in important environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment, a preliminary scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

A gender-based analysis plus (GBA+) assessment concluded that the amendment is unlikely to result in differential impacts on the basis of identity factors, such as gender, race, ethnicity, sexuality or 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 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 an entity believed to be engaged in activities that directly or indirectly support, provide funding for, or contribute to a violation of the sovereignty or territorial integrity of Ukraine. Therefore, these sanctions are unlikely to have a significant impact on vulnerable groups as compared to traditional broad-based economic sanctions directed toward a state. In so far as sanctions limit Russia’s ability to wage war, individuals and groups vulnerable to gender-based discrimination are likely to benefit from these measures.

Implementation, compliance and enforcement, and service standards

The amendment comes into force on the day it is registered.

The name of the listed entity 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 amendment.

The Trade Commissioner Service at Global Affairs Canada continues to assist clients, abroad and in Canada, 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.

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