On September 22, 2023, during Ukrainian President Volodymyr Zelensky’s visit to Canada, Canada announced amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”) sanctioning additional Russian individuals and entities. The amendments list an additional 42 individuals and 21 entities under Schedule 1 of the Regulations and took effect on September 20, 2023.

At the press conference announcing the sanctions, Canadian Prime Minister Justin Trudeau stated that the aforementioned persons are sanctioned in response to their involvement in the illegal forcible mass transfer and detention of Ukrainian children, the generation and dissemination of disinformation and propaganda, as well as association with Russia’s nuclear programs. Notable individuals sanctioned in the new amendments include Anton Kotyakov, the Minister of Labor of the Russian Federation, and Alexey Petrov, the advisor to the Commissioner for Childrens’ Rights. Noteable sanctioned entities include the Moscow State Institute of International Relations and the newspaper Komsomolskaya Pravda.

Schedule 1 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 new deeming provision under the Special Economic Measures Act, read our previous blog post on Canada’s July 2023 Russia sanctions here.

Since February 2022, Canada has continually updated the Regulations, as well as the Special Economic Measures (Belarus) Regulations and the Special Economic Measures (Ukraine) Regulations. 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 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 September 20, 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.