On February 24, 2025, the Government of Canada announced further amendments to the Special Economic Measures (Russia) Regulations (“the Russia Regulations”). These amendments list an additional 44 entities and 32 individuals, both Russian and non-Russian, in Schedule 1 of the Russia Regulations. The designated entities and individuals include those who support Russia’s military-industrial complex, facilitate the transport of military equipment within Russia, or are associated with the unlawful deportation and forced transfer of Ukrainian children from the temporarily occupied territories of Ukraine.
This recent round of sanctions marks the Government of Canada’s second use of its authority to impose secondary sanctions, following the 2023 amendments to the Special Economic Measures Act. These amendments designated Iranian and Chinese entities under Schedule 1. From a policy perspective, these listings differ slightly from the first round of secondary sanctions issued by the Government of Canada; the listings target entities alleged to be facilitating activities to support Russia’s war in Ukraine.
These amendments also expand existing prohibitions under the Russia Regulations. Specifically, Schedule 7 was amended to include prohibitions on the export of certain goods used in the manufacture of weapons. Additionally, an existing prohibition on ships docking in Canadian ports now prohibits Canadians and persons in Canada from contracting with certain ships. This prohibitions specifically targets Russia’s ‘Shadow Fleet’ by sanctioning 109 vessels involved in transporting property and goods for the benefit of Russia or individuals in Russia.
The Regulations impose 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:
(a) dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
(b) entering into or facilitating any transaction related to a dealing in a designated person’s property;
(c) providing any financial or related services in respect of a dealing in a designated person’s property;
(d) making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
(e) 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
(f) 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.
Businesses should continually assess their sanctions compliance in this shifting legal landscape and should note that the Russia Regulations no longer only list Russian persons and entities due to the Government’s use of its secondary sanctions authority. The Russia Regulations now list persons and entities of other nationalities, including Chinese, Dutch, Irish, and Iranian. Regulations made under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property owned or controlled by Schedule 1 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 Schedule 1 entities. An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on February 21, 2025 are available on Global Affairs Canada’s website here.
