On May 11, 2026, Canada announced new amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments, effective as of May 8, 2026, impose sanctions on 23 individuals and 5 entities.

Since 2014, Canada has imposed sanctions on more than 3,400 individuals and entities “that are complicit in the violation of Ukraine’s sovereignty and territorial integrity, and in gross and systematic human rights violations”. Canada has stated that the intent of the new measures is to “deter, expose, and condemn human rights violations committed by Russian authorities and their local collaborators during Russia’s war of aggression against Ukraine by imposing costs on those involved in the unlawful deportation, forcible transfer, indoctrination, and militarization of Ukrainian children”.

Prior to these amendments, Canada had previously sanctioned over 80 individuals and entities for their “involvement in violations of the rights of Ukrainian children in Russia and in the temporarily occupied territories of Ukraine”.

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 Adhithya Krishnan

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