The sanctions package at a glance

A significant new sanctions package was announced on June 17, 2025, enacted through three separate amendments to the Special Economic Measures (Russia) Regulations, and came into force retroactively on June 13, 2025. This is one of the biggest sanctions packages against Russia since 2022.

New sanctions were placed on 77 individuals, 39 entities, and 201 ships in Russia’s “shadow fleet,” including oil and gas tankers and cargo ships.

The sanctions aim to remove Canada as an export market for a wider range of Russian revenue-generating goods by placing new prohibitions on certain imports from Russia. The sanctions also aim to further limit the supply of goods and services to Russia that could benefit Russia’s economy and military-industrial complex. 

Newly sanctioned individuals and entities 

An additional 77 individuals and 39 entities were sanctioned, meaning they are subject to asset freeze and dealings prohibition restrictions. The Canadian government has stated that these include government and private sector actors who support Russia’s military industrial complex and disinformation, persons who enable Russia’s shadow fleet, persons benefiting from the war, and persons involved in the development of the quantum sector. 

New prohibited imports from Russia 

The amendments create prohibitions on certain imports from Russia and persons in Russia, including in relation to sectors such as coal and metals. 

A new schedule with a wider subset of Russian “revenue-generating goods” was created, which includes both consumer products (such as cosmetics, cigars, clothing, bags, precious metals and perfumes) and industrial products or raw materials (helium, nitrates, certain chemicals, etc.).

There are certain limited exceptions for newly added goods and goods pursuant to existing contracts, for limited periods of time following the implementation date of the sanctions. 

New prohibited exports to Russia 

The amendments create additional export prohibitions, including the supply of jet fuel and additives, and chemicals and related goods (such as fume hoods, respirators, laboratory equipment, DNA and RNA sequencers and component parts) that could be used for chemical or biological weapons.

There are certain limited exceptions for newly added goods and goods pursuant to existing contracts, for limited periods of time following the implementation date of the sanctions. 

Amendment to sanctions on provision of services to ships

The amendments include new restrictions on and in relation to the servicing of an additional 201 listed ships, including oil tankers and cargo ships believed to be part of Russia’s shadow fleet.

Updated disclosure requirements

The amendments require disclosure by anyone possessing or controlling property that they believe is owned or controlled by a sanctioned person to either the RCMP or to CSIS. Previously the reporting requirement was solely to the RCMP.

Recommendations 

The Government of Canada continues to expand and strengthen Canada’s sanctions against Russia, now directly sanctioning over 3,300 Russian individuals and entities in addition to countless more entities which are deemed to be owned or controlled by these sanctioned persons.

In May 2025, the RCMP arrested and charged a Canadian businessman for allegedly violating Canada’s sanctions prohibiting technology trade and exports to Russia. These were the first charges for such an offence under the Special Economic Measures (Russia) Regulations.

Canadian businesses contemplating transactions, or with operations potentially impacted by the new sanctions, should review their due diligence and compliance policies and practices, supply chains and partners, in order to ensure any adjustments and compliance as may be required. 

The members of our team have significant experience in Canadian sanctions matters and are happy to discuss them with you to assist with your compliance efforts.



Contacts

Partner
Partner

Recent publications

Subscribe and stay up to date with the latest legal news, information and events . . .