On June 17, 2025, Canada announced its “biggest-ever” package of vessel- and trade-related sanctions against Russia since Russia’s full-scale invasion of Ukraine in February 2022.
The amendments to the Special Economic Measures (Russia) Regulations (Russia Regulations) impose sanctions on 77 additional individuals, 39 additional entities and 201 additional vessels, as well as new prohibitions on trading in nearly 1,000 additional goods with Russia. The new restrictions enter into force immediately.
New Import Restrictions
The new amendments aim to remove Canada as an export market for a wide range of goods by which Russia gains revenue, including coal, metals, and a variety of industrial and consumer goods.
The Russia Regulations now prohibit the import, purchase or acquisition of the following goods, wherever situated, from Russia or any person in Russia:
- Coal and coal products, including lignite, peat, coke, goal gas, tar, pitch and pitch coke, and oils and other products distilled from coal
- Metals, including new restrictions on copper, nickel, tin, zinc, lead, magnesium, tungsten, cobalt and manganese, and expanded sanctions on iron, steel and aluminum, as well as a range of products made from any of those metals, including tools and cutlery
- Revenue-generating goods, including a variety of consumer and commercial goods, such as mineral or chemical fertilizers, wood, nails and screws, hand tools, locks and keys, furniture, semiconductors, tractors, carbon, and nitrates, among many other goods
These amendments significantly expand the existing restrictions on the import of goods previously listed in the Russia Regulations, such as luxury goods, gold and diamonds.
New Export Restrictions
The new amendments expand export restrictions to include additional industrial goods, sensitive technologies with dual-use applications and various chemicals with dual-use applications. The Russia Regulations now prohibit the import, purchase or acquisition of the following goods, wherever situated, from Russia or any person in Russia:
- Jet fuel and additives, including oxidation inhibitors and fuel system icing inhibitors
- Various chemicals, including common chemicals such as acetone, acetylene, ammonia, arsenic, chlorine, ethanol, methanol, potassium bromide or sulphur
- Advanced or sensitive technologies with dual-use applications, including equipment designed for the production of ultra-efficient solar cells, precision machine tools, lithium and lithium compounds and rare earth minerals, among others
New Sanctions on Individuals and Entities
The new amendments add 116 new individuals and entities to Schedule 1 of the Russia Regulations, bringing the total to over 2,400 “designated persons” listed on Schedule 1.
The Russia Regulations impose a comprehensive ban on any dealing in property that is owned, held or controlled by a designated person and prohibit providing financial services or making available goods to such persons. This prohibition extends to any property of a non-designated entity that is controlled by a designated person. Control under the Special Economic Measures Act is defined very broadly, as described in our Blakes Sanctions Primer.
New designations added to Schedule 1 include a Russian oil and gas company and various entities and individuals involved in the quantum technology sector, among others.
Expanded and Additional Vessel Sanctions
The new amendments include new sanctions against an additional 201 Russia-linked vessels, which the Canadian government has concluded are involved in transporting oil, liquefied natural gas, arms and other goods benefiting Russia. Over 300 Russia-linked vessels are now sanctioned by Canada.
Canada has also increased the restrictions applicable in respect of these vessels. The Russia Regulations now prohibit any person in Canada and any Canadian outside Canada from providing any services related to any of the listed vessels to a non-Canadian outside Canada. Previously, Canada’s sanctions had more narrowly prohibited the docking of listed vessels in Canada and their passage through Canada.
Exceptions
The new sanctions on goods contain grandfathering exceptions for certain goods imported or exported under a contract that was entered into at least 60 days before the date of the new sanctions, provided those goods are imported or exported within 120 days after the contract date.
A New Landscape
Now more than ever, Canadian businesses should carefully assess business relationships and transactions to determine whether any activities may contravene any prohibitions in the Russia Regulations. Sanctions against designated persons and dealings with non-designated persons are broader than ever.
For additional details regarding Canada’s sanctions laws, see our Blakes Sanctions Primer.
For more information, please contact the authors or any other member of our International Trade group.
