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SOR/2025-33 is an earlier round in the same recurring series of Special Economic Measures (Russia) Regulations amendments as the later 2025-06-13 (SOR/2025-142) and 2025-11-12 (SOR/2025-228) filings already in this register — Canada has used this instrument since 2014 to build out its Russia sanctions list. This regulation was registered and came into force on 2025-02-21; Global Trade Alert logged the corresponding state act the same day, so announced_date and effective_date are both set to the registration date.
Three target clusters, per the Gazette regulatory impact statement:
1. Shadow-fleet vessels — 109 vessels added to the new Schedule 1.1 by IMO number rather than name, to resist evasion via re-flagging/renaming: 92 oil tankers and 9 LNG tankers moving Russian energy exports, and 8 vessels moving arms/related material between Russia, Iran and North Korea. This predates and is extended by the UK OFSI (2025-01-13), Canada's own June and November 2025 rounds, and the EU Council's December 2025 shadow-fleet listings already filed in this register. 2. Military-industrial base and hybrid capability — individuals and entities tied to defence manufacturing, sensitive-technology flows, airlines and insurance supporting Russia's war effort. 3. Circumvention and atrocity-linked designations — entities described in the regulatory text as sanctions-evasion networks and disinformation agents, plus designations tied to the forced deportation of Ukrainian children and filtration-point operators in occupied territories.
Severity is set at 3 (quant basis), anchored on the Gazette's own counts: 32 individuals, 44 entities and 109 vessels added in a single amending regulation. That is a larger single listing round than the June 2025 (34 entities, 201 vessels) and November 2025 (13 individuals, 11 entities, 100 vessels) Canadian rounds already in the register, but it is still one incremental amendment to an already-large, multi-year cumulative Canadian Russia sanctions list rather than a first-of-kind or economy-wide measure — consistent with the severity-3 rating given to the sibling filings in this series.
(alongside the UK/EU/US actions and Canada's later 2025 rounds already filed) ahead of those later rounds — raising insurance, flagging and port-access friction for the tagged tankers globally.
early instance of Canada using the SEMA vessel-schedule mechanism against the DPRK/Iran arms-supply corridor, not just the oil/LNG price-cap evasion fleet.
later June/November 2025 Canadian rounds (would indicate re-designation after evasion, not new targets).