On June 16, 2026, Canada announced new amendments to the Special Economic Measures (Russia) Regulations (the “Regulations”).

These amendments, effective as of June 12, 2026, repeal subsections 8(3) and 8(4) of the Regulations, which previously required the Minister of Foreign Affairs (the “Minister”) to make a decision on delisting applications within 90 days of receipt and to notify applicants of the decision without delay. According to Canada, these subsections are being repealed “to support procedural fairness and accountability in the review process”. While the Regulations continue to permit listed individuals and entities to apply for delisting, the removal of these provisions eliminates the express statutory timeline for ministerial decisions and the corresponding notice requirement.

The amendments also impose sanctions on 7 individuals, 34 entities, and 121 vessels associated with Russia’s shadow-fleet operations, and its military-industrial and energy sectors. The amendments to Schedule 1 target individuals and entities including “senior leadership and related entities supporting the Russian defense-industrial base and revenue-generating strategic sectors, particularly energy, nuclear services and financial enablers, including cryptocurrency”. Additionally, Canada has amended Schedule 1.1 to target vessels from “Russia’s shadow fleet”. Since 2014, Canada has imposed sanctions on more than 3,400 individuals and entities as well as over 600 vessels “to hold Russia accountable”.

We regularly assist clients with the application for delisting process and subsequent judicial review of determinations (or lack thereof) by the Minister 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 Denyses Barthelemy Giron