Expanded Russia sanctions and export ban

Summary#

These are final regulations called Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2024-32. They add people and companies to Canada’s Russia sanctions lists and expand the list of goods Canadians cannot export to Russia, including explosives and a range of high-tech and mechanical parts. The rules came into force when registered on February 21, 2024 and were published in the Canada Gazette on March 13, 2024.

What it does#

• Removes the old term “designated person” and changes the rules so Canada can list people or companies outside Russia (including in third countries).
• Adds 10 named individuals and 153 entities to Schedule 1 of the sanctions list. These are firms and people identified as supporting Russia’s military or helping it evade sanctions.
• Expands the export ban in Schedule 7 to include:
  • HS Code 36 — explosives and related items (this covers detonators and charges used in mining and construction).
  • Electronic and data-processing components (for example, 8471.50, 8471.80).
  • Antennas and related parts (8529.10, 8529.90).
  • Bearings and related mechanical parts (8482.10, 8482.20, 8482.30, 8482.50).
  • Machines used to make semiconductors and related production/testing equipment (8486.10, 8486.20, 8486.40, 9027.50, 9030.20, 9030.32, 9030.39, 9030.82).
  • Optical and navigation devices (for example, 9013.10, 9013.80, 9014.20, 9014.80).
• Makes it illegal for Russian-registered ships, or ships used/leased for or on behalf of Russia or listed persons, to dock in or pass through Canada — except when needed to protect life or navigational safety.
• Keeps and clarifies some limited financial/loan exceptions so certain transfers or loan repayments can continue where appropriate.
• Allows anyone listed in Schedule 1, 2 or 3 to apply in writing to the Minister to be removed from the list.
• Creates a process for people who share a name with someone on a list to get a certificate saying they are not the listed person. The Minister has 30 days to issue the certificate if the person is clearly not the listed individual.

Who's affected#

• The 10 individuals and 153 entities newly added to Schedule 1 (many are companies linked to Russia’s defence, shipping, insurance and industrial sectors).
• Canadian exporters and businesses that trade in explosives, bearings, semiconductor-making machines, optics, antennas and other listed goods. (The government notes recent trade with Russia in these items is very small.)
• Banks and other financial institutions in Canada that must screen for and block deals with listed persons.
• Shipping companies and crews of Russian-flag or Russia-used vessels that would otherwise try to enter or pass through Canadian waters.
• People who share a name with a listed person (they can apply for a mistaken-identity certificate).
• It is unclear how many third‑country firms or non-Russian individuals will be added in future, but the law now allows listing people who are not based in Russia.

Why it matters#

• The changes strengthen Canada’s ability to target people and companies helping Russia’s military effort or evading sanctions. That aims to make it harder for Russia to buy parts, equipment or services it could use in the war in Ukraine.
• Adding HS Code 36 (explosives and detonators) responds to concerns that civilian-use explosives could be repurposed for military attacks.
• The export bans and asset/transaction prohibitions mean listed persons effectively face an asset freeze and trade restrictions from Canada. Listed individuals may also be found inadmissible to Canada under the Immigration and Refugee Protection Act.
• Enforcement is handled by agencies such as the Royal Canadian Mounted Police and Canada Border Services Agency, and penalties include fines and prison: on summary conviction up to $25,000 or 1 year in jail (or both), and on indictment up to 5 years in prison.
• For most Canadians the direct impact will be limited, because overall trade with Russia in the newly listed categories is reported to be low. But firms that export the listed goods or work in shipping and finance will need to follow the new rules.