On August 28, 2025 Canada announced  new amendments to the Special Economic Measures (Moldova) Regulations (the “Regulations”). These amendments impose sanctions on another 16 individuals and 2 entities “for their role in Russia’s malign interference activities in Moldova”.

To date, Canada has sanctioned 32 individuals and 9 entities, as listed in the Schedule of the Regulations. According to Canada, certain individuals and entities have been sanctioned as a result of their direct support of the Shor party, which was sanctioned in June 2023 “in response to its continued efforts to destabilize the democratically elected Moldovan government in favour of Russia”. Canada’s sanctions also include “former officials of Moldova and officials of the Autonomous Territorial Unit of Gagauzia, a region in Moldova whose current administration has strong links to Russia”, and “representatives of pro-Russian media from Moldova engaged in disseminating disinformation”.

We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minster of Foreign Affairs in response to those applications for delisting. We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.

Authors: Michelle Folinas and Maria Mateus

Should you have any questions regarding these developments or sanctions generally, please contact: