On February 24, 2026, Canada announced new amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments, effective as of February 19, 2026, impose sanctions on 21 individuals, 53 entities, and 100 vessels. Additionally, amendments were made to Schedule 10.01 to lower the oil price cap (OPC) per barrel on Russian crude oil from US$47.60 to US$44.10.

Since 2014, Canada has imposed sanctions on more than 3,300 individuals and entities “that are complicit in the violation of Ukraine’s sovereignty and territorial integrity, and in gross and systematic human rights violations”. The most recent amendments target individuals “who contribute directly or indirectly to Russia’s war efforts, including individuals involved in an energy trading network, financial actors enabling sanctions evasion, and persons involved in Russia’s artificial intelligence ecosystem, drone production and hybrid warfare capabilities”. Canada alleges that the entities subject to this round of sanctions are “linked to Russia’s energy revenues, financial enablers, AI ecosystem, drone production, and procurement networks”.

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.

Author: Michelle Folinas

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