The Canadian sanctions regime has continued to evolve incrementally in late 2025 and early 2026. Over the last several months, Canada has:

  • Recalibrated its country-specific sanctions regime.
  • Provided additional guidance to compliance with Canada’s sanctions regime, which we wrote about in November 2025 and April 2024.

This update is an overview of increased sanctions relating to Russia and Iran and the easing of sanctions against Syria as well as a recap of Global Affairs Canada’s (GAC) recent update to the sanctions guidance.

Russia

Canada’s sanctions against Russia remain the most extensive and actively enforced component of Canada’s sanctions regime. The sanctions were initially imposed through the Special Economic Measures (Russia) Regulations (the Russia Regulations) in March 2014 following Russia’s occupation of the Crimea. Since Russia’s full‑scale invasion of Ukraine in February 2022, Canada has repeatedly expanded the scope and breadth of its sanctions measures and sanctions targets, and has begun taking enforcement actions.

On the fourth anniversary of Russia’s invasion, Canada announced a further package of sanctions listing 21 individuals, 53 entities, and approximately 100 vessels associated with Russia’s “shadow fleet.” Canada also recently lowered its oil price cap on Russian crude oil from US$47.60 to US$44.10 per barrel, in keeping with likeminded nations, the United Kingdom and the European Union.

These measures support Canada’s objective of increasing the economic costs on Russia for its aggression against Ukraine by restricting Russia’s energy revenues and financial infrastructure and degrading Russia’s military capabilities.

Notably, 2025 saw developments in several sanctions enforcement actions under the Russia Regulations:

  • Continued RCMP investigations into Dmitry Shelkov and Digonta Technology, including an order authorizing further detention of devices seized under a search warrant.
  • Charges brought against Anton Trofimov and his company, Asia Pacific Links Ltd. in May 2025 following a three-year investigation by the RCMP’s Sanctions Unit.
  • A notice of application filed on March 18, 2025 to forfeit a seized Antonov aircraft, which is owned, held, or controlled by two sanctioned Russian entities. This is the first forfeiture proceeding under the Special Economic Measures Act.

Iran

On February 13, 2026, Canada amended the Special Economic Measures (Iran) Regulations (Iran Regulations) to sanction seven individuals linked to Iranian state bodies identified as responsible for intimidation, violence, and transnational repression targeting Iranian dissidents and human rights defenders. These sanctions follow Canada’s amendment of the Iran Regulations to allow imposing sanctions against individuals and entities engaged in destabilizing activities in the Middle East and globally that undermine international peace, security or stability.

Further developments to the Iran Regulations are anticipated as the Government of Canada reassesses its approach in light of ongoing geopolitical developments in the Middle East.

Syria

In February 2026, Canada significantly amended the Special Economic Measures (Syria) Regulations (Syria Regulations) to ease restrictions against Syria, after several likeminded countries took similar steps in 2025.

The amendments lifted broad sectoral prohibitions on imports and export of goods, investment activities and the provisions of financial and other services. These prohibitions, which had been in place since May 2011, were linked to the former Assad regime.

Additionally, Canada de‑listed two individuals and 24 entities to reduce barriers to economic activity and enable transactions with state-affiliated entities, including banks and other institutions in the petroleum, financial services, and media sectors.

The General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations, under which individuals could apply to carry out activities and transactions otherwise prohibited under the Syria Regulations, is no longer necessary. The activities that were previously only temporarily allowed under the General Permit are now legal under Canadian law. The validity of the period of the General Permit was, accordingly, not extended beyond its expiration on February 23, 2026.

These amendments aim to ease barriers to economic activity and enable transactions in order to facilitate humanitarian-related and other transactions in Syria.

At the same time, Canada introduced two new designation criteria under the Syria Regulations to enable designating individuals and entities involved in gross and systematic human rights violations or conduct undermining Syria’s peace, security or stability. Six individuals were sanctioned under the new criteria.

GAC’s guidance

As a result of an internal GAC evaluation recommending publishing comprehensive written guidance, the Sanctions Bureau released additional guidance on compliance with Canada’s sanctions regime in November 2025.

The new guidance covers:

  • Essential information on Canada’s sanctions regime,
  • Compliance program implementation.
  • A non-exhaustive list of “red flags” that may help to detect suspicious transactions or sanctions evasion.
  • Sector-specific guidance for the financial, academic and research, real estate, and humanitarian sectors.

See here for more information on the sector-specific guidance.

While the guidance offers some useful high-level insight, it repeats much of GAC’s existing materials, and provides limited practical direction.

GAC also expanded its Frequently Asked Questions (FAQ) page to address Canada’s enforcement of sanctions compliance and the application of sanctions to academic institutions.

The FAQ places particular emphasis on the Russia Regulations, including the designation of ships and direction on how the Russia Regulations apply in practice. This includes clarifying the definition of “dealings” with designated persons, the treatment of indirect or extraterritorial transactions, and potential liability arising from employment with a non-Canadian employer not in compliance with Canada’s sanctions regime.