Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2026-188
Canada Gazette, Part II, Volume 160, Number 19
Registration
SOR/2026-188 September 4, 2026
SPECIAL ECONOMIC MEASURES ACT
P.C. 2026-787 September 4, 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 1 of Schedule 1 to the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in numerical order:
- 1616 Denis Sergeyevich CHERNOBAY (born on August 7, 2002)
- 1617 Grigory Alexandrovich GUROV (born on October 31, 1985)
- 1618 Vladimir Viktorovich KHROMOV (born on August 15, 1977)
- 1619 Alexandra Dmitrievna KULGINA (born on February 16, 2001)
- 1620 Aleksandr Vyacheslavovich KURENKOV (born on June 2, 1972)
- 1621 Elena Igorevna MILSKAYA (born on December 20, 1980)
- 1622 Artur Valeriyevich ORLOV (born on March 15, 1989)
- 1623 Vitaliy Aleksandrovich SUK (born on March 12, 1970)
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
Since Russia first invaded Ukraine in 2014, Russian authorities have unlawfully deported Ukrainian children to Russia and forcibly transferred others within the temporarily occupied territories of Ukraine. Russia significantly expanded these practices after launching its full-scale war of aggression against Ukraine in 2022. Thousands of Ukrainian children have been subjected to unlawful deportation, forcible transfer, destruction of their identity, militarization, indoctrination and other grave violations of international law and have remained under the control of the Russian Federation. To further deter, expose and condemn these violations, Canada is amending the Special Economic Measures (Russia) Regulations (the Russia Regulations) to impose sanctions against an additional eight individuals.
Background
Ukrainian children are subjected to a range of state-imposed measures aimed at assimilating them into Russian society. These include, but are not limited to, forced acquisition of Russian citizenship and unlawful adoption or placement with Russian families, both in Russia and in the territories of Ukraine temporarily occupied by Russia. These measures are also often accompanied by efforts to erase Ukrainian identity through the suppression of the Ukrainian language, culture and national symbols.
Russia’s actions pose major humanitarian, human rights and legal challenges for the international community. These actions constitute violations of international law, including the Geneva Conventions and the United Nations (UN) Convention on the Rights of the Child.
International response
In March 2023, the International Criminal Court issued arrest warrants for Russian President Vladimir Putin and Russia’s Presidential Commissioner for Children’s Rights, Maria Lvova-Belova, in relation to the unlawful deportation and unlawful transfer of children from occupied areas of Ukraine to Russia. Under international law, this is considered a war crime.
Canada and Ukraine co-chair the International Coalition for the Return of Ukrainian Children, launched in February 2024, which aims to return Ukrainian children home to their families and communities. It brings together 47 partner states and 3 international organizations to coordinate diplomatic efforts; strengthen data and tracing mechanisms; support rehabilitation and reintegration; and advance accountability. Coalition members continue to increase pressure on Russia to cooperate in securing the immediate, safe and unconditional return of Ukrainian children.
Canada, Ukraine and Norway co-chair the Working Group on the Human Dimension in Kyiv. The Working Group addresses the broader humanitarian consequences of Russia’s war, including efforts to secure the return of Ukrainian prisoners of war, unlawfully detained civilians and deported children, grounded in international humanitarian law and international human rights law.
In October 2024, Canada co-hosted the Ministerial Conference on the Human Dimension of Ukraine’s Peace Formula in Montréal, with Ukraine and Norway. A key outcome was the endorsement of the Montreal Pledge by 54 countries and organizations, a political and operational commitment to support the safe return, reintegration, and rehabilitation of Ukrainian prisoners of war, unlawfully detained civilians and deported children.
In September 2025, the Prime Minister of Canada co-hosted, alongside the President of Ukraine, a High-Level Meeting of the International Coalition for the Return of Ukrainian Children on the margins of the 80th session of the UN General Assembly. The meeting, which brought together over 50 delegations, including heads of state and government, reaffirmed the shared humanitarian imperative of returning and reintegrating Ukrainian children.
In December 2025, Canada played a leadership role, alongside Ukraine and the European Union (EU), in co-facilitating the UN General Assembly resolution on the return of Ukrainian children, which demands that the Russian Federation ensure the immediate and unconditional return of Ukrainian children who have been unlawfully deported and forcibly transferred.
On May 11, 2026, Canada, the EU and Ukraine co-hosted a High-Level Meeting of the International Coalition for the Return of Ukrainian Children in Brussels. Participants advanced coordinated efforts to trace, return, rehabilitate and reintegrate affected children, strengthen diplomatic pressure and accountability, and coordinate sanctions.
Underscoring these ongoing international efforts, Canada’s partners continue to sanction those responsible for unlawful actions against Ukrainian children. These measures include sanctions announced by the EU and the United Kingdom (U.K.) in May 2026 against individuals and entities involved in the unlawful deportation and forcible transfer of Ukrainian children.
Through a combination of Ukraine’s state-led efforts, international mediation, and civil society initiatives, more than 2 400 Ukrainian children have been returned since 2022. Thousands more remain in Russia and in the temporarily occupied territories of Ukraine, separated from their families and communities.
Canada’s response
The Government of Canada has been clear and consistent in condemning these acts of the Russian government towards Ukrainian children and has actively worked through diplomatic channels, multilateral engagement and international assistance programming to support Ukraine’s efforts to secure the safe return of children and to ensure their rehabilitation and reintegration.
As part of Canada’s comprehensive response to Russia’s full-scale invasion of Ukraine, since 2014, the Government has imposed extensive economic measures, including sanctions against more than 3 500 individuals and entities, under the Special Economic Measures Act (SEMA) in response to Russia’s violations of Ukraine’s sovereignty. This includes sanctions against those involved in violations of the rights of Ukrainian children.
Objective
The objectives of the Regulations Amending the Special Economic Measures (Russia) Regulations (the amendments) are to deter, expose and condemn human rights violations committed by Russian authorities and their local collaborators in Russia’s war of aggression against Ukraine by imposing costs on those involved in the unlawful deportation, forcible transfer, indoctrination and militarization of Ukrainian children.
Description
The amendments add eight individuals that have engaged in key activities, in the past or presently, that indirectly or directly facilitate the Russian government’s violation of the rights of Ukrainian children, including their unlawful deportation and forcible transfer, and their exposure to indoctrination and militarization. These designations include officials and public figures in Russia and in temporarily occupied territories of Ukraine. Many of these individuals have been sanctioned by other countries. The role of these individuals in Russia’s illegal actions towards Ukrainian children has been well documented by non-government organizations and credible media outlets. 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 Schedule 1, 2 or 3. 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 and discourage individuals from contributing, directly or indirectly, to Russia’s war efforts.
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) and Immigration, Refugees and Citizenship Canada (IRCC) will incur a small cost to ensure their relevant systems include the persons listed through these amendments.
Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed individuals to their existing monitoring systems, 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 individuals.
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 listed in the amendments have limited linkages with Canada and do not have business dealings that are significant to the Canadian economy. It is therefore anticipated that there will be minimal impacts on Canadians or Canadian businesses as a result of these 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. Global Affairs Canada does not anticipate any applications resulting from listing these persons because no business dealings significant to Canada’s economy have been identified.
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 and entities included in the amendments.
Canadian small businesses are subject to the duty to disclose under the Russia Regulations, which represent a direct compliance requirement. However, as the newly listed individuals have no known legitimate linkages with Canada, Global Affairs Canada does not anticipate any disclosures resulting from the amendments.
One-for-one rule
The one-for-one rule does not apply, as there is no incremental change in administrative burden on businesses. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act. However, while permits may be granted under the Special Economic Measures Permit Authorization Order on an exceptional basis, given the minimal level of trade with Russia, 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 individuals 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 EU, Japan, New Zealand, Switzerland, the U.K. and the United States. Sanctions are most effective when they are applied in a coordinated manner.
International obligations
Compliance with Canada’s international commitments was considered in the development of the 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
None of the listed individuals have Canadian citizenship. A gender-based analysis 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 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 towards 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 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, 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