On November 12, 2025, Canada announced new amendments to the Special Economic Measures (Russia) Regulations (the “Russia Regulations”) to impose sanctions against 13 individuals, 11 entities, and 100 vessels from Russia’s “shadow fleet”. Canada states that these new measures target Russia’s “energy revenues and financial enablers, while also degrading its conventional and hybrid military capabilities”.

According to Canada, the newly sanctioned individuals and entities include several who are involved in “the development and deployment of Russia’s drone program”, two Russian liquified natural gas entities, and one of the entities’ executives. Also included in this new round of sanctions are Kremlin-linked individuals and entities “that supply the cyber infrastructure used in Russian hybrid strategies against Ukraine”, which Canada notes it is doing for the first time. Canada considers itself “a leader in targeting the military technologies Russia is relying on in its efforts to gain a battlefield advantage against Ukraine”.

To date, Canada has sanctioned over 3,300 individuals and entities, and over 400 vessels under the Russia Regulations.

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: Stephanie Desjardins, Michelle Folinas, and Hugh Jones

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