On June 16, the Government of Canada announced an aggressive sanctions package, effective as of June 13, 2025, implementing a number of amendments to the Special Economic Measures (Russia) Regulations (the “Regulations“).
These amendments designated a further 116 individuals and entities, which Canada has described as follows: Kremlin enablers and oligarchs, persons involved in the development of sensitive dual-use quantum technology, beneficiaries of the illegal war in Ukraine, ‘Shadow Fleet’ enablers, banks and foreign financial institutions. Canada has extended its prohibition on vessel docking to include a ban on all services related to listed vessels and has added 201 Russia-linked vessels to the existing vessels list in the Regulation. Finally, Canada has implemented new trade restrictions on various items, such as industrial goods and materials related to chemical and biological weapon. As part of the new trade restrictions, Canada placed import restrictions on items like coal, metals, and products that generate revenue for Russia. Most of the trade prohibitions include provisions for delayed implementation and exceptions for prior contracts to allow time for industry adjustment.
New Trade Prohibitions
Coal: Persons in Canada and Canadians are prohibited from importing, purchasing or acquiring certain coal products listed in column 1 of Schedule 5.01 (e.g. coal, lignite, peat, coke, coal gas, tar distilled from coal) wherever situated, from Russia or from any person in Russia. This prohibition comes into force on August 12, 2025, but allows limited-time exception for goods imported, purchased, or acquired under a contract made before June 13, 2025, provided that such goods are imported, purchased, or acquired within 120 days after August 12, 2025.
Jet Fuel: Persons in Canada and Canadians are prohibited from exporting, selling, supplying or shipping certain jet fuel products listed in column 1 of Schedule 5.02 (e.g. spirit-type jet fuel, kerosene-type jet fuel, oxidation inhibitors), wherever situated, to Russia or to any person in Russia. The amendments include an exemption for the “usual and reasonable quantities of goods stored on board an aircraft and intended for consumption on board the aircraft during its outgoing and return flight”. This prohibition comes into force on August 12, 2025, but allows limited-time exception for goods imported, purchased, or acquired under a contract made before June 13, 2025, provided that such goods are imported, purchased, or acquired within 120 days after August 12, 2025.
Chemical Weapons and Biological Weapons: Persons in Canada and Canadians are prohibited from exporting, selling, supplying, or shipping any goods referred to in Schedule 10.1, wherever situated, to Russia or to any person in Russia. The amendments also carve out certain exemptions, including for those goods used to support international nuclear safeguards verifications.
Revenue Generating Goods: Persons in Canada and Canadians are prohibited from importing, purchasing, or acquiring any good referred to in column 1 of Schedule 13, wherever situated, from Russia or from any person in Russia. Schedule 13 consists of a wide variety of goods (218 items in total), including crustaceans, cigars, Portland cement, helium, nitrates, tires, leather, suitcases, and furskins. This prohibition comes into force on August 12, 2025, but allows exception for the following:
- Goods exported from Russia at least 60 days before this prohibition comes into force (i.e., goods exported before June 13, 2025).
- Goods that are personal effects taken by an individual leaving Russia that are solely for the use of the individual or the individualâs immediate family; and
- Goods that are imported, purchased, or acquired under a contract made before June 13, 2025, provided that such goods are imported, purchased, or acquired within 120 days after August 12, 2025.
Expanded or Revised Prohibitions
Industrial Goods: Section 3.09(1) of the Regulations prohibits the export, sale, supply, or shipment of goods listed in Schedule 7 to Russia or any person in Russia. This heading of this section has been revised from âGoods-manufacture of weaponsâ to refer to âIndustrial Goodsâ and Schedule 7 has been amended to include additional restricted items. The amendments also introduce a new exception to the expanded prohibition for “goods used in relation to the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, infrastructure, or the environment.”
This expanded industrial goods prohibition comes into force on August 12, 2025. There is a time-limited exception for newly listed Schedule 7 goods that were exported, sold, supplied, or shipped under a contract entered into before June 13, 2025, provided that such goods are exported, sold supplied or shipped within 120 after August 12, 2025.
Steel & Aluminum: The existing prohibition on steel and aluminum goods listed in Schedule 11 was revised to include additional steel and aluminum goods subject to the import prohibition. This expanded prohibition comes into force on August 12, 2025, and does not apply to goods (existing or newly listed Schedule 11 steel and aluminum goods) if a contract for the import, purchase or acquisition of the goods was entered into before March 10, 2023. For newly listed Schedule 11 steel and aluminum goods, a time-limited exception applies for any goods that were either exported from Russia before June 13, 2025, or imported, purchased or acquired under a contract made before June 13, 2025, provided that such goods are imported, purchased, or acquired within 120 days after August 12, 2025.
Effects of designation under the Russia Regulations
The Regulations impose dealings prohibition against the individuals listed, effectively freezing any assets they hold in Canada. The dealing prohibition on designated individuals and entities came into force on June 13, 2025. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
- dealing in any property, wherever situated, that is owned â or that is held or controlled, directly or indirectly â by a designated person;
- entering into or facilitating any transaction related to a dealing in a designated personâs property;
- providing any financial or related services in respect of a dealing in a designated personâs 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.
Businesses should continually assess their sanctions compliance in this shifting legal landscape. The Regulations 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.
This sanctions package was implemented through three separate amending regulations, and an unofficial copy of the legislative amendments are linked here, here, and here.
