On August 28, 2025, Canada announced amendments to the Special Economic Measures (Moldova) Regulations (the “Regulations”) sanctioning Russian collaborators in Moldova. The amendments list an additional sixteen individuals and two entities under the Schedule of the Regulations and took effect on August 28, 2025. These sanctions are announced in the context of Moldova’s upcoming parliamentary elections, which will be held on September 28, 2025, and are aimed at individuals who are stated to have been actively participating in coordinated efforts aimed at destabilizing the democratically elected government in Moldova.
The sanctioned individuals are stated to be associated with Ilan Mironovich Shor, a politician and businessman, who has already been sanctioned by Canada and fled Moldova in 2019 and Shor’s political party, the Shor Party, which has also been sanctioned by Canada for its alleged continued efforts to destabilize the democratically elected Moldovan government in favour of Russia. Additional sanctioned individuals and entities include: former officials of Moldova, officials of the Autonomous Territorial Unit of Gagauzia (a region in Moldova whose current administration has strong links to Russia), the Shor-led political bloc, Victory/Pobeda (the successor of the Shor Party) and a Shor-backed paramilitary group and its leaders.
The Schedule of the Regulations imposes a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
- 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.
For more information on Canada’s first round of sanctions under the Regulations in June 2023, read our previous blog post here.
Canada has continued to update the Regulations, as well as the Special Economic Measures (Russia) Regulations, the Special Economic Measures (Belarus) Regulations and the Special Economic Measures (Ukraine) Regulations to sanction individuals and entities complicit in the violation of Ukraine’s sovereignty and territorial integrity. 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 owned or controlled by the Schedule entities and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property owned, held or controlled by the Schedule entities.
An unofficial copy of the legislative amendments to the Special Economic Measures (Moldova) Regulations that came into effect on August 28, 2025 are available on Global Affairs Canada’s website here.
