Regulations Amending the Special Economic Measures (Russia) Regulations: SOR/2024-90

Canada Gazette, Part II, Volume 158, Number 12

SOR/2024-90 May 16, 2024


P.C. 2024-518 May 16, 2024

Whereas the Governor in Council is of the opinion that the actions of the Russian Federation constitute a grave breach of international peace and security that has resulted in a serious international crisis;

Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Special Economic Measures (Russia) Regulations under paragraph 4(1)(a)footnote a and subsections 4(1.1)footnote b, (2)footnote c and (3) of the Special Economic Measures Act footnote d.

Regulations Amending the Special Economic Measures (Russia) Regulations


1 Part 1 of Schedule 1 to the Special Economic Measures (Russia) Regulations footnote 1 is amended by adding the following in numerical order:

2 Part 2 of Schedule 1 to the Regulations is amended by adding the following in numerical order:

Application Before Publication

3 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.

Coming into Force

4 These Regulations come into force on the day on which they are registered.


(This statement is not part of the Regulations.)


Since 2023, the Democratic People’s Republic of Korea (North Korea) and Russia have rapidly scaled up arms cooperation, including the transfer of ammunition and ballistic missiles, which have been linked to civilian casualties in Ukraine. Individuals and entities in the Russian transportation sector facilitate the acquisition of weapons, equipment, and technology from North Korea for use by the Russian government in its illegal invasion of Ukraine.


On February 24, 2022, Russian President Putin announced “a special military operation” as Russian forces launched a full-scale invasion of Ukraine from Russian and Belarusian territory, which continues in May 2024. Heavy fighting persists in eastern and southern Ukraine. As part of its military strategy, Russia continues to fire missiles and kamikaze drone attacks on essential civilian infrastructure. As of February 2024, the United Nations (UN) Human Rights Monitoring Mission in Ukraine has confirmed at least 10 000 civilians have been killed and 20 000 injured since February 24, 2022. Furthermore, 444 medical facilities and 1 055 educational facilities in Ukraine have been damaged or destroyed by Russia’s military since the invasion.

Since August 2023, North Korea has provided significant quantities of ammunition and other materiel to Russia, including ballistic missiles. Several governments, non-governmental organizations and the United Nations Security Council (UNSC) Panel of Experts have reported that Russia is procuring North Korean arms and munitions directly from North Korea via commercial cargo vessels and aircraft. The materiel is processed at various Russian ports on its Pacific coast before being transported via rail to munitions depots near Russia’s border with Ukraine.

Ukrainian officials reported that Russian forces have launched North Korean missiles dozens of times against Ukraine (including at least three ballistic missiles), resulting in civilian casualties. In December 2023 and March 2024, Ukrainian officials reported that Russia used North Korean short-range ballistic missiles in Ukraine. This is corroborated by open-source research by the non-governmental organization Conflict Armament Research. Research published in January 2024 and the assessment by the UNSC Panel of Experts in April 2024 conclude that debris recovered from a missile that landed in Kharkiv, Ukraine, on January 2, 2024, was from a North Korean short-range ballistic missile.

International response 

The coalition of countries supporting Ukraine against Russia’s illegal invasion includes, but is not limited to, G7 and European countries and some of Ukraine’s neighbours. This group is working to support Ukraine across a number of areas, including energy security, nuclear safety, food security, humanitarian assistance, combatting Russian disinformation, sanctions and economic measures, asset seizure and forfeiture, military assistance, accountability, recovery and reconstruction. Canada and G7 countries are engaged diplomatically with the broader international community to encourage support for Ukraine and counter false Russian narratives. Key votes in multilateral forums have effectively isolated Russia, including resolutions in the UN General Assembly (UNGA) condemning Russian aggression against Ukraine (March 2022), deploring the humanitarian consequences of Russian aggression against Ukraine (March 2022), suspending Russian membership in the UN Human Rights Council (HRC) (April 2022) and condemning Russia’s illegal annexation of Ukrainian territories (October 2022).

North Korea has indicated its support for Russia’s invasion of Ukraine since 2022 and continues to do so, including by voting against UN resolutions that condemn Russian action. North Korea also recognized Russia-controlled Donetsk and Luhansk in 2022. Russia has used its privileged position as a Permanent Member of the UNSC to advocate for lifting sanctions on North Korea, including by blocking additional resolutions and, most recently, vetoing the renewal of a UNSC Panel of Experts mandated to investigate sanctions evasions related to North Korea. Russia’s lone veto (China abstained) cut off a major source of public, credible, and independent reporting on North Korean sanctions evasion, including North Korean arms transfers to Russia.

Canada’s response 

Following Russia’s illegal occupation and attempted annexation of Crimea in March 2014, the Government of Canada, in tandem with partners and allies, enacted sanctions through the Regulations under the Special Economic Measures Act (SEMA). The Special Economic Measures (Russia) Regulations (the Russia Regulations) impose dealings prohibitions (an effective asset freeze) on listed individuals and entities supporting or enabling Russia’s violation of Ukraine’s sovereignty. Any person in Canada and Canadians outside Canada are prohibited from dealing in the property of, entering into transactions with, providing services to, or otherwise making goods available to persons listed under Schedules 1, 2 or 3 of the Russia Regulations.

In coordination with its international partners, Canada has imposed sanctions on more than 3 000 individuals and entities in Russia, Belarus, Ukraine and Moldova, who are complicit in the violation of Ukraine’s and Moldova’s sovereignty and territorial integrity and human rights abuses. In addition, Canada has implemented targeted restrictions against Russia in financial, trade (goods and services), energy and transport sectors.


The specific objectives of imposing these measures are to


The amendments to the Russia Regulations add two individuals and six entities to Schedule 1 of the Regulations, who have been engaged in activities that support Russia’s invasion of Ukraine, including by facilitating the transportation of ammunition, ballistic missiles, and other materiel from North Korea to Russia. The two individuals are senior officials at companies known to be transporting weapons from North Korea to Russia. The entities are companies that own shipping, air cargo and other logistics capabilities that transfer North Korean cargo, including containers, to military support facilities in Russia.

Any person in Canada or Canadians outside Canada is thereby prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed individuals and entities (persons). These measures will also render listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act.

Under the Russia Regulations, listed persons may apply to the Minister of Foreign Affairs to have their name removed from the schedule of designated persons. The Minister must determine whether there are reasonable grounds to make a recommendation to the Governor in Council for removal.

Regulatory development


Global Affairs Canada engages regularly with relevant stakeholders, including civil society organizations, cultural communities and other like-minded governments, regarding Canada’s approach to sanctions implementation.

With respect to the amendments, public consultation would not be appropriate. Publicizing the names of the persons targeted by sanctions would have potentially resulted in asset flight prior to the coming into force.

Modern treaty obligations and Indigenous engagement and consultation

An initial assessment of the geographical scope of the initiative was conducted and did not identify any modern treaty obligations, as the Russia Regulations do not take effect in a modern treaty area.

Instrument choice

Regulations are the sole method to enact sanctions in Canada. No other instrument could be considered.

Regulatory analysis

Costs and benefits

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions is minimal. Sanctions targeting specific individuals and entities also have less impact on Canadian businesses than traditional broad-based economic sanctions and have limited impact on the citizens of the country of the listed individuals and entities. Based on the initial assessment of available open-source information, it is believed that the individuals listed have limited linkages with Canada and, therefore, do not have significant business dealings that are relevant to the Canadian economy. It is therefore anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of these amendments.

Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed individuals and entities to their existing monitoring systems, which may result in a compliance cost.

Small business lens

With respect to the persons being listed under the Russia Regulations, analysis under the small business lens concluded that the regulatory amendments will not impact Canadian small businesses. The amendments prohibit Canadian businesses from dealing with, providing services to, or otherwise making goods available to listed persons, but do not create obligations related to them. While Canadian businesses may seek permits under the Russia Regulations, they are granted on an exceptional basis. Global Affairs Canada does not anticipate any applications resulting from listing these; thus, there would be no incremental administrative burden arising from this requirement. Canadian small businesses are also subject to the duty to disclose under the Russia Regulations, which would represent a direct compliance requirement. However, as the newly listed individuals have limited known linkages with Canada, Global Affairs Canada does not anticipate any disclosures resulting from the amendments.


The one-for-one rule does not apply as there is no incremental change in administrative burden on business. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act. However, while permits may be granted under the Russia Regulations, on an exceptional basis, given these individuals and entities are closely linked to Russia’s military-industrial complex, have no known business ties to the Canadian economy and are sanctioned in other jurisdictions as well, Global Affairs Canada does not anticipate any permit applications with respect to the amendments.

Regulatory cooperation and alignment

While the amendments are not related to a work plan or commitment under a formal regulatory cooperation forum, they align with actions taken by Canada’s international partners.

The duration of sanctions by Canada and like-minded partners has been explicitly linked to the peaceful resolution of the conflict and the respect for Ukraine’s sovereignty and territorial integrity within its internationally recognized borders, including Crimea and Ukraine’s territorial sea. Canada’s international partners continue to update their sanction regimes against individuals and entities in Russia and enforce far-reaching trade and investment prohibitions on Russia.

Many of Canada’s like-minded partners, including Australia, the European Union, New Zealand, the United Kingdom, and the United States, have also adopted sanctions in response to the North Korea-Russia arms transfer under their respective autonomous sanction regimes.

Strategic environmental assessment

The amendments are unlikely to result in important environmental effects. In accordance with the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary scan concluded that a strategic environmental assessment is not required.

Gender-based analysis plus

The subject of economic sanctions has previously been assessed for effects on gender and diversity. Although intended to facilitate a change in behaviour through economic pressure on individuals and entities in foreign states, sanctions under the SEMA can nevertheless have an unintended impact on certain vulnerable groups and individuals. Rather than affecting Russia as a whole, these targeted sanctions impact individuals believed to be engaged in activities that directly or indirectly support, provide funding for or contribute to a violation of the sovereignty or territorial integrity of Ukraine. Therefore, the amendments are unlikely to have a significant impact on vulnerable groups compared to traditional broad-based economic sanctions directed toward a state.

Implementation, compliance and enforcement, and service standards

The amendments come into force on the day on which they are registered.

Consequential to being listed in the Russia Regulations and pursuant to the application of paragraph 35.1(b) of the Immigration and Refugee Protection Act, the listed individuals would be inadmissible to Canada.

The names of the listed individuals and entities will be available online for financial institutions to review and will be added to the Consolidated Canadian Autonomous Sanctions List. This will help to facilitate compliance with the Russia Regulations.

The Department’s Trade Commissioner Service abroad and in Canada continues to assist clients in understanding Canadian sanctions regulations, and notably the impact of the Russia Regulations on any activities in which Canadians may be engaged. The Department is also increasing outreach efforts across Canada — including engaging with businesses, universities, and provincial/territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

Under the SEMA, both Royal Canadian Mounted Police and Canada Border Services Agency officers have the power to enforce sanctions violations through their authorities as defined under the Customs Act, the Excise Act or the Excise Act, 2001, and sections 487 to 490, 491.1 and 491.2 of the Criminal Code.

In accordance with section 8 of the SEMA, every person who knowingly contravenes or fails to comply with the Russia Regulations is liable, upon summary conviction, to a fine of not more than $25,000 or to imprisonment for a term of not more than one year, or to both; or, upon conviction on indictment, to imprisonment for a term of not more than five years.


Sanctions Bureau (PSD)
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