On November 10, 2023, Canada announced additional amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). The amendments list an additional 9 individuals and 6 entities under Schedule 1 of the Regulations and took effect on November 9, 2023.

The Canadian Minister of Foreign Affairs, the Honourable Mélanie Joly, stated that the sanctioned persons and entities “directly promote Russia’s war of aggression against Ukraine” via their participation in Kremlin-backed disinformation and war propaganda to legitimize the war through narratives framed as expert opinion. Currently, more than 2,700 individuals and entities in Russia, Belarus, Ukraine and Moldova have been sanctioned by Canada for “complicit[y] in the violation of Ukraine’s sovereignty and territorial integrity”.

Further amendments were made to the Regulations on November 9, 2023 which removed four individuals from Schedule 1 of the Regulations: Alexandra Yurievna Buriko, Lev Aronovich Khasis, Natalya Andreevna Alymova and Aleksandra Melnichenko. In July 2023, Khasis was delisted from the UK sanctions list. In September 2023, Alymova was delisted from the US sanctions list.

Generally speaking, designation under Schedule 1 of the Regulations imposes an asset freeze and dealings prohibition against the designated person. Subject to limited exceptions, any person in Canada or any Canadian outside Canada cannot:

  • deal in any property, wherever situated, that is owned, held or controlled by or on behalf of a designated person whose name is listed in Schedule 1;
  • enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
  • provide any financial or other related services in respect of such a dealing;
  • make available any goods, wherever situated, to a designated person listed in Schedule 1 or to a person acting on their behalf; or
  • provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1.

Additionally, individuals listed in Part 1.1 of Schedule 1 of the Regulations are also 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 entities and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property held by Schedule 1 entities.

An unofficial copy of the legislative amendments to the Special Economic Measures (Russia) Regulations that came into effect on November 9, 2023 are available on Global Affairs Canada’s website here


Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.