On October 17, 2023, Canada announced amendments to the Special Economic Measures (Moldova) Regulations (the “Regulations”) sanctioning Russian collaborators in Moldova. The amendments list an additional nine individuals and six entities under the Schedule of the Regulations and took effect on October 16, 2023. These sanctions are announced in the context of the fourth meeting of the Moldova Support Platform occurring in Chisinau, Moldova. The platform coordinates international support for Moldova in the midst of the crisis triggered by Russia’s war of aggression against Ukraine.

The sanctioned individuals are associated with influential oligarchs who have previously been sanctioned by Canada, such as Vladimir Plahotniuc and Ilan Mironovich Shor. Some of the sanctioned individuals are also connected to Shor’s political party, the Shor Party, which has also been sanctioned by Canada for its continued efforts to destabilize the democratically elected Moldovan government in favour of Russia. The sanctioned entities are television stations that actively promote and disseminate Russian disinformation to justify Russia’s war against Ukraine and have had their operating licenses revoked by Moldova’s Commission for Exceptional Situations.

The Schedule of the Regulations imposes a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act. For more information on the dealings prohibition and 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 October 16, 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.