Sanctions: Canada Hits Russia Hard

Canada targets 300+ new designations and trade bans in one of its toughest sanctions packages since 2022. Are you prepared?

Introduction

As a Sanctions Compliance professional, you know that sanctions are fast-moving, often politically charged, and always legally binding. Canada’s newest sanctions package against Russia, enacted in June 2025, exemplifies just how serious the global compliance landscape has become. With sweeping new restrictions targeting individuals, entities, vessels, and trade, this development is a wake-up call for all trade compliance, OFAC, and OFSI professionals.

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Key Questions Covered in This Blog

Part I – New Listings

• Who are the 77 individuals and 39 entities added to Canada’s sanctions list?

• Why are 201 ships now designated, and what makes up Russia’s "shadow fleet"?

Part II – New Trade Measures

• What new Russian goods are banned from import into Canada?

• What are the new export restrictions, including chemicals and jet fuel?

• Are there exceptions for contracts or goods in transit?

Part III – Other

• What are the updated disclosure rules for sanctioned property?

• How does this affect Canadian compliance obligations and penalties?

"Canada has gone from reactive to assertive—this sanctions package signals a proactive, zero-tolerance stance against economic enablers of Russian aggression."Arne Mielken, Managing Director, Customs Manager Ltd

Abbreviations Used In This Blog

• SEMA – Special Economic Measures Act

• RCMP – Royal Canadian Mounted Police

• CSIS – Canadian Security Intelligence Service

• OFSI – UK Office of Financial Sanctions Implementation

• OFAC – U.S. Office of Foreign Assets Control

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Part I – New Listings

Who are the 77 individuals and 39 entities added to Canada’s sanctions list?

Canada added 77 individuals and 39 entities in one of its largest single expansions of sanctioned parties since 2022. This includes figures from Russia’s disinformation apparatus, private and state-linked military suppliers, enablers of the quantum technology sector, and individuals profiting from the Ukraine war. These additions are now subject to asset freezes and a prohibition on dealings by any person in Canada or Canadian abroad. For compliance professionals, this means enhanced screening obligations and immediate system updates.

Why are 201 ships now designated, and what makes up Russia’s "shadow fleet"?

The 201 newly listed vessels are believed to be part of Russia’s so-called shadow fleet—tankers and cargo ships used to evade sanctions, operate under flag-of-convenience registries, and move Russian crude oil despite Western bans. Canada has now restricted any servicing, insuring, or facilitating activity connected to these ships. The implication for trade compliance teams is clear: enhanced vessel screening is no longer optional—it’s essential.

Part II – New Trade Measures

What new Russian goods are banned from import into Canada?

Canada expanded its list of revenue-generating goods that can no longer be imported. These now include:

• Consumer items such as cosmetics, cigars, perfumes, bags, and apparel

• Industrial inputs like nitrates, helium, and specific chemicals

The rationale? Cut off funding pipelines to the Russian state. The import bans also apply to indirect shipments—e.g., goods shipped via third countries. If you are an importer, your supplier declarations and routing audits must be airtight.

What are the new export restrictions, including chemicals and jet fuel?

Canada also introduced new export bans, targeting products that can support Russian military and scientific development. These include:

• Jet fuel and additives

• Lab equipment such as fume hoods, respirators, DNA/RNA sequencers

All of these fall under concerns that they may support chemical or biological weapons programs. If you're involved in export compliance, your end-use and end-user checks must now factor in these new layers.

Are there exceptions for contracts or goods in transit?

Yes, but they are limited and time-bound. Contracts signed before the ban's effective date may be honoured—but only within narrow timeframes. There are also exceptions for humanitarian, diplomatic, and civil aviation uses. Always consult the actual regulation or seek a SEMA permit where appropriate.

Part III – Other

What are the updated disclosure rules for sanctioned property?

A major change: Any individual or company that knows or suspects they control or hold property for a sanctioned person must now report not just to the RCMP, but also to CSIS. This new two-agency model means a higher reporting burden and more scrutiny.

How does this affect Canadian compliance obligations and penalties?

This package sends a message: Non-compliance has teeth. In May 2025, Canada arrested a businessman for violating export sanctions to Russia—the first known criminal charge under SEMA. Fines, prosecution, and reputational damage are no longer theoretical. If your firm trades internationally, a sanctions compliance program isn’t optional—it’s survival.

Arne’s Takeaway

Canada’s latest sanctions are broad, deep, and enforcement-driven. You must act now: update your screening systems, audit your supply chains, reassess your due diligence. The time to be reactive has passed—proactive compliance is the only way forward.

Expert Recommendations

• Update internal sanctions lists immediately to reflect new designations.

• Enhance vessel screening with maritime intelligence tools.

• Audit imports and exports tied to Russia—ensure origin and end-use documentation is verifiable.

• Train staff on the new obligations, especially dual-reporting to RCMP and CSIS.

• Apply for SEMA permits if you rely on any exceptions.

  
  

Sources & Further Information

• Government of Canada, Global Affairs Canada: SEMA Regulations

• Canada Gazette Notices (June 2025 Sanctions Package)

• RCMP and CSIS Guidance on Reporting Obligations

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Disclaimer

This blog is for educational purposes only and does not constitute legal advice. Always consult legal counsel for specific compliance questions.

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