On November 12, 2025, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the Regulations). These amendments list an additional 13 individuals and 11 entities under Schedule 1 of the Regulations and took effect on November 6, 2025. These newly listed entities and individuals are stated to enable Russia’s energy sector and hybrid warfare strategies, including suppliers of cyber infrastructure and companies linked to liquefied natural gas operations that help finance military activities. This is the first time Canada has sanctioned actors supporting Russia’s cyber capabilities.
- dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
- entering into or facilitating any transaction related to a dealing in a designated person’s property;
- providing any financial or related services in respect of a dealing in a designated person’s property;
- making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
- transferring or providing any property other than goods to a listed person or to a person outside Canada who is not Canadian for the benefit of a designated person; or
- providing any financial or related services to or for the benefit of a designated person.
Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.
The amendments also list an additional 100 shipping vessels considered to be part of Russia’s shadow fleet under Schedule 1.1 of the Regulations. It is prohibited for any person in Canada and any Canadian outside Canada to provide, to a person outside Canada who is not Canadian, any services related to a listed vessels on Schedule 1.1.
Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property held by Schedule 1 parties and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property of Schedule 1 parties.
An unofficial copy of the legislative amendments to the Regulations that came into effect on November 6, 2025, are available on Global Affairs Canada’s website here.
