Canada expands scope of sanctions from ban on luxury goods to a wider scope of Russian exports

On June 13, 2025, Canada amended the Special Economic Measures (Russia) Regulations, (the “SEMA Russia Regulations”) to increase existing sanctions on Russia.

The SEMA Russia Regulations, which seek to sanction enablers of Russian advancement in the territory of Ukraine, already included asset freezes and dealings bans on entities and individuals affiliated with the Russian state, Russian military activities, and those benefitting from Russia’s advancement and circumvention of existing sanctions, notably through the operation of its “shadow fleet” of vessels engaged in trade on behalf of Russia and persons in Russia. Previous sanctions also included a ban on exporting certain industrial equipment and deemed luxury goods.

The amendments, which came into force on June 13, 2025, expanded the scope of existing list-based sanctions to include 116 new listed persons and entities (including 3 newly listed financial institutions), as well as 201 new vessels considered to be part of Russia’s “shadow fleet,” in alignment with previous amendments.

In addition, this latest package of Canadian sanctions includes import and export prohibitions on new categories of goods in the energy and industrial sectors.

This includes:

• A new prohibition on imports and purchases of Russian coal products by Canadians or persons in Canada;
• A new prohibition on exports and sales to Russia of jet fuels and additives by Canadians or persons in Canada;
• A broadening of the existing prohibition on exports and sales to Russia of industrial goods by Canadians or persons in Canada. Previously, this prohibition applied chiefly to goods and materials with potential uses for the manufacture of weapons. These additions significantly expand the scope of export prohibitions beyond goods with direct or indirect military applications.
• A new prohibition on exports and sales to Russia of materials potentially used for the manufacture of chemical and biological weapons by Canadians or persons in Canada. This prohibition includes the substances themselves, as well as accessory materials, equipment, parts and consumables.
• A new prohibition on imports and purchases of certain Russian metals by Canadians or persons in Canada. This prohibition applies to common, general-use metals such as iron, steel, aluminum, copper, nickel, as well as certain rare and specialty metals.
• A new prohibition on imports and purchases of certain “revenue-generating goods” from Russia by Canadians or persons in Canada. This new prohibition covers a broad variety of goods and includes food and agricultural products, construction materials, chemicals, minerals, machinery and equipment, motor vehicles, as well as consumer goods.

Many of the new prohibitions on imports and exports include an exemption period of 60 days before coming into force and include a longer exemption period of 120 days for contracts entered into in the 60 days prior to the entry into force of this latest amendment. However, there is no such exemption for goods related to the production of chemical and biological weapons.

This latest expansion represents an important development in Canadian sanctions, as it has the potential to affect industry sectors which had remained less touched by sanctions thus far. It will require all organizations operating in Canada to exercise heightened caution in their cross-border business dealings to ensure compliance with these added restrictions on imports and exports. Our international trade team is able to support you on matters of economic sanctions. We invite you to contact the authors of this article for any questions on this topic.