Canada Targets Russia With Sweeping Sanctions Package, Including New Import And Export Prohibitions

On June 17, 2025, the Government of Canada unveiled a substantial expansion of its sanctions measures against Russia, introducing wide-ranging new import and export prohibitions. Described by officials as "one of Canada's most important sanctions announcements since Russia began its full-scale invasion of Ukraine," these measures mark a significant escalation in Canada's economic response to Russia's ongoing aggression.¹ In this round of updates, Canada has:

Prohibited imports of coal, various metals and "revenue generating goods";
Prohibited exports of jet fuel and additives and certain products related to chemical and biological weapons;
Prohibited the provision of services related to Russian ships as well as expanding the list of Russian vessels subject to various prohibitions; and
Adding several new Russian individuals and entities to the list of persons subject to the dealings prohibition.

Each of these prohibitions and the effect on international businesses is discussed below.

New Import Prohibitions on Coal, Certain Metals and Revenue Generating Goods

On August 12, 2025,² over 1,000 new categories of goods will be subject to an import prohibition. These include:

Coal and its related materials including briquettes, peat (including peat litter), and coal gas;³
Metals and machinery made of metal, including iron, steel, railway or tramway track construction materials, stoves/ranges, grates, cookers, kitchen or other household articles like steel wool or scouring pads, tractors, motor vehicles, racing cars, tanks, motorcycles, transport containers, optical fibres, binoculars, surgical, dental, or veterinarian appliances, video game consoles, and snow skis, to name a few⁴;
Over 200 forms of "revenue-generating goods" including crustaceans, cigars, various forms of fertilizers, several forms of chemicals, mechanical appliances, synthetic rubber, pneumatic tires, polymers, paper and paperboard, leather, turbo jets, suits and shoes, yachts and other pleasure craft, among others.⁵

Generally, these prohibitions do not apply if the goods are imported under a contract entered into before June 13, 2025 and the goods are imported within 120 days of entry into force. Any imports under contracts entered into after June 13, 2025 would not fall under exception and therefore are prohibited.

Import Prohibition	Entry into Force	Wind Down Period
Coal	60th day after the day on which these Regulations are registered, which was June 13, 2025: August 12, 2025	Contract entered into at least 60 days before entry into force: June 13, 2025	Goods are imported with 120 days of entry into force
Newly Added Metals
Revenue Generating Goods

There are additional exceptions available with respect to the importation of certain metals depending upon the metal involved and the date of contract. Businesses potentially implicated by this prohibition should carefully review the covered goods and assess the date of contract to assess whether the prohibition might apply.

Export Prohibitions on Jet Fuel and Products Related to Chemical and Biological Weapons

The amendments also expand export prohibitions from Canada. New prohibitions on export include:

Jet fuel and its additives such as sprit-type and kerosene-type jet fuels, including those blended with biodiesel;⁶
Goods and chemicals related to chemical and biological weapons like acetone, arsenic, carbon monoxide, fentanyl, isopropanol, and mercury.⁷

Similar to the import prohibitions, there is a wind down period for the jet fuel prohibition. The prohibition does not apply if the goods are exported under a contract entered into before June 13, 2025, and the goods are exported within 120 days of entry into force.

The export ban on goods related to chemical and biological weapons comes into force 30 days after June 13, 2025. There is no wind down period for exports that would be covered under this ban. This ban does have limited exceptions, such as for use in support of nuclear safeguard verifications, goods necessary for the safe operation of aircraft or ships, or goods urgently needed to prevent or mitigate events that could seriously impact human health and safety, infrastructure, or the environment, among other narrowly defined circumstances.⁸

Canada already controls the export of goods that can be used in relation to chemical and biological weapons primarily under Group 7 of its Export Control List (ECL), as well as any goods with potential dual-use capabilities in Group 1 of the ECL.⁹ Further, in 2022, Global Affairs Canada released a notice, indicating that it would not issue export permits for any goods being exported to Russia.¹⁰ However, this new amendment expressly prohibits the export of these chemicals (rather than a permit denial policy) and seemingly covers a wide range of chemical precursors and commercially available chemicals, such that it is broader than what is currently covered under the ECL.

Prohibition on the Provision of Vessel Services

Canada has further tightened restrictions on Russian maritime activity. Previously, Canada prohibited listed Russian vessels from docking in or transiting through Canadian waters. The latest measures go further—Canadians are now prohibited from providing any services to the 310 Russian vessels now designated under Canada's sanctions regime.

According to Canada's Minister of Foreign Affairs, this expanded prohibition is intended to "constrain the activities of vessels that are part of Russia's shadow fleet " ¹¹,a network of oil tankers used to transport Russian oil and petroleum products globally while circumventing international sanctions.

These prohibitions came into force on June 13, 2025.

Newly Sanctioned Individuals and Entities

Finally, the amendments add 116 new individuals and entities to Canada's dealings prohibitions, including Russian oligarchs (such as Vladimir Sergeevich Lisin of Novolipetsk Steel (NLMK) as well as individuals and entities involved in the development of sensitive dual-use quantum technology.¹² These additions bring the total number of Russian individuals and entities sanctioned in Canada to approximately 3,000.

Canadian Sanctions Enforcement: Recent Charges Laid by the RCMP

On May 5, 2025, the Royal Canadian Mounted Police (RCMP) arrested Mr. Anton Trofimov, charging him with one count of exporting controlled goods to Russia and one count of exporting goods intended for weapons manufacturing.¹³ The RCMP alleges that Mr. Trofimov's company, Asia Pacific Links Ltd., a company sanctioned in both the United States and the United Kingdom, exported goods to Russia through intermediary countries. These goods are reportedly used in the production of Orlan-10 drones, which the Russian military employs for reconnaissance and airstrikes in Ukraine.

This arrest is a rare but significant example of Canada's recent enforcement of its sanctions regime and highlights the cross-border coordination required to support such actions. Canadian authorities involved in the investigation include the RCMP, the Canada Border Services Agency (CBSA), the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), and Global Affairs Canada, working in partnership with the U.S. Federal Bureau of Investigation.

While Canadian enforcement activity in this space remains relatively limited, the consequences of violating sanctions are severe. Businesses should ensure their sanctions compliance programs are current and fully account for the recently expanded prohibitions.

Recap of Canada's Russia Sanctions To-Date

Given this new and broad sanctions package, it is useful for businesses to understand the complete scope of Canada's sanctions with respect to Russia as they stand today. There are:

Dealings prohibition in relation to almost 3,000 Russian individuals and entities;
Restrictions on providing new debt and equity financing to certain listed banks;
Restrictions on providing equipment for use in oil exploration and production;
Prohibitions on Russian vessels from docking and transiting through Canada;
Import prohibitions on petroleum oil and gases from Russia;
Import prohibitions for goods listed on the Restricted Goods and Technologies List;
Prohibitions on providing aviation and aerospace related insurance or reinsurance;
Import and export prohibitions related to luxury goods;
Prohibitions on the export of goods that can be used in the manufacture of weapons;
Import prohibitions related to Russian gold and diamonds;
Prohibitions on providing several services in relation to various Russian industries, like mining, manufacturing of various equipment, and oil extraction;
Prohibitions on providing services related to the marine transportation of crude oil and petroleum products;
Prohibitions on the import and export of arms and related material
Prohibitions on the import of steel and aluminum from Russia; and
Assisting in any of the above prohibited activities.

Footnotes

1. Global Affairs Canada, News Release, Minister Anand announces major additional sanctions in relation to Russia's war of aggression against Ukraine (June 17, 2025).

2. These three prohibitions come into force 60 days after the amending regulations were published, which was on June 13, 2025.

3. Special Economic Measures (Russia) Regulations SOR/2025-143, Subsection 3.051(1) and Schedule 5.01.

4. Special Economic Measures (Russia) Regulations SOR/2025-143, subsection 3.14(1) and Schedule 11.

5. Special Economic Measures (Russia) Regulations SOR/2025-143, Subsection 3.16(1) and Schedule 13.

6. Special Economic Measures (Russia) Regulations SOR/2025-143, subsection 3.052 (1) and Schedule 5.02.

7. Special Economic Measures (Russia) Regulations SOR/2025-143, subsections 3.131(1) and (2).

8. Special Economic Measures (Russia) Regulations SOR/2025-143, subsection 3.131(3).

9. Government of Canada, A Guide to Canada's Export Control List (May 2025).

10. Global Affairs Canada, Notice to exporters and brokers – Export and brokering of items listed on the Export Control List and the Brokering Control List to Russia (February 24, 2022).

11. Global Affairs Canada, News Release, Minister Anand announces major additional sanctions in relation to Russia's war of aggression against Ukraine (June 17, 2025)

12. Special Economic Measures (Russia) Regulations, SOR/2025-141, Part 1 of Schedule 1.

13. RCMP News Release, RCMP arrest individual for exporting banned technology to Russia (June 6, 2025).

The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.