On 24 February 2026, marking the fourth anniversary of Russia’s full‑scale invasion of Ukraine, Canada announced a further significant expansion of its sanctions regime under the Special Economic Measures (Russia) Regulations (Regulations), effective February 19, 2026. The measures form part of Canada’s continuing effort to constrain Russia’s military operations.
Expansion of Designations
The amendments list multiple individuals to Part 1 of Schedule 1, including persons linked to: Russia’s financial and procurement networks; entities supporting military and dual‑use technology development; and activities undermining Ukraine’s sovereignty and territorial integrity.
A defining feature of the February 2026 amendments is the significant expansion of entity listings in Part 2 of Schedule 1, targeting Russia’s military and hybrid‑warfare strategy. In particular, listing entities operating in Russia’s artificial intelligence, cybersecurity, data processing and digital infrastructure sectors. Newly designated entities include: AI research institutes and alliances, technology firms supporting drone production and battlefield surveillance, cybersecurity and software companies involved in defensive and offensive digital capabilities; and digital infrastructure providers, including data‑processing and cryptocurrency‑related firms.
The Regulations impose a dealings prohibition against the individuals listed in Schedule 1, 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.
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.
Continued Action Against Sanctions Evasion and Energy Revenues
The amendments also form part of a broader package of measures aimed at degrading Russia’s ability to evade sanctions and generate energy‑related revenues. Canada has emphasized its ongoing focus on: financial actors facilitating sanctions circumvention; infrastructure enabling the movement, financing or insurance of restricted oil shipments; and entities supporting Russia’s efforts to bypass G7‑aligned restrictions. To this effect, Canada has sanctioned an additional 100 vessels from Russia’s shadow fleet and lowered its price cap for Russian crude oil from US$47.60 to US$44.10 per barrel.
An unofficial copy of the legislative amendments to the Regulations that came into effect on February 19, 2025, are available on Global Affairs Canada’s website here.
