On June 17, 2025 Canada announced three new amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”). These amendments impose additional sanctions on individuals and entities, as well as expand on Canada’s vessel sanctions and trade prohibitions. 

The first and second amendments impose sanctions on an additional 77 individuals and 39 entities to Schedule 1 of the Regulations. Canada has stated their reasons for sanctioning certain individuals and entities include their direct support of “the Kremlin in moving funds in and out of Russia to pay for arms and other war-related material”, and their involvement “in the development of the quantum sector in Russia”. Canada’s sanction list also includes individuals and entities that have “benefited from the war, including some of the wealthiest Russian industrialists, senior government officials and persons involved in the confiscation and redistribution of property and assets of foreign companies in Russia”, as well as individuals “identified by the Anti-Corruption Foundation”.

Canada has also listed an additional 201 vessels under Schedule 1.1 of the Regulations to “constrain the activities of vessels that are part of Russia’s shadow fleet”. To date, Canada has sanctioned over 300 Russia-linked vessels “involved in the movement of oil, liquefied natural gas, arms and other items for the benefit of Russia”.

The third amendment imposes additional export restrictions on “goods related to the production of chemical and biological weapons as well as industrial goods and advanced sensitive technologies with dual-use applications”. These new export restrictions include “goods related to the production of chemical and biological weapons as well as industrial goods and advanced sensitive technologies with dual-use applications”. Additionally, new import restrictions apply to “coal, metals and a variety of other goods through which Russia gains revenue from exporting overseas”. Many of the trade prohibitions include delayed coming into force provisions and prior contracts exceptions “to enable sufficient time for industry adjustment”.

Our team will continue to closely monitor the sanctions related to Russia, providing updates to keep clients informed about important developments affecting trade and services. 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 also regularly assist with applications for exemption permits, including under the Special Economic Measures (Russia) Permit Authorization Order. 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 Madalina Fetescu

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