Canada sanctions 100 Russian shadow-fleet vessels, 13 individuals and 11 entities including Kyrgyzstan-based evasion enablers

Mechanism

SOR/2025-228 is the latest in a long-running series of amendments to the Special Economic Measures (Russia) Regulations that Canada has used since 2014 to build out its Russia sanctions list (cumulative total now over 3,300 individuals/entities plus 400+ vessels per Tereposky & DeRose). The regulation was made (registered) on 2025-11-06 and came into force on registration; Minister Anand's public announcement followed on 2025-11-12, which is also the date Global Trade Alert logged the intervention. This filing uses the Gazette registration date as effective_date and the public announcement date as announced_date.

Three distinct target clusters are notable:

1. Energy revenue — LNG-trading entities are added to Schedule 1.1, consistent with Canada's stated aim of constraining the energy revenue funding Russia's war effort. 2. Military/hybrid capability — individuals tied to drone-programme development, and — for the first time in a Canadian SEMA amendment per the law-firm summary — entities supplying cyber infrastructure used in Russian hybrid operations against Ukraine. 3. Third-country evasion hubs — Kyrgyzstan-based Capital Bank of Central Asia and the A7 (A7A5) payments platform are designated as financial enablers, reflecting Kyrgyzstan's emergence as a hub for Russia sanctions-evasion (ruble-stablecoin and correspondent-banking workarounds flagged by the EU and other G7 partners in parallel actions). 4. Shadow-fleet vessels — 100 vessels added by IMO number to Schedule 1.1, aligned with the UK OFSI (2025-01-13) and EU Council shadow-fleet listings (2025-12-15, 2025-12-18) already in this register, extending the G7's coordinated effort to squeeze the tanker fleet Russia uses to move sanctioned crude/LNG outside the price cap.

Severity is set at 3 (quant basis) reflecting a bounded but meaningful listing round — 13 individuals, 11 entities, 100 vessels — that is incremental to an already-large cumulative Canadian Russia list, rather than a first-of-kind or economy-wide measure.

Downstream implications

• Extends the G7 shadow-fleet vessel-designation perimeter (alongside UK/EU/US

actions already filed) — increasing insurance, flagging and port-access friction for the tagged vessels globally, not just in Canadian waters.

• First Canadian SEMA designation of cyber-infrastructure suppliers signals

Ottawa is following the EU/US template of sanctioning hybrid-warfare enablers, not just kinetic/military and financial targets.

• Kyrgyzstan-based designations (Capital Bank of Central Asia, A7) add to a

building G7 case against Bishkek-domiciled financial rails as a sanctions work-around channel — watch for reciprocal EU/US/UK designations of the same entities and for Kyrgyzstan's diplomatic response.

Open questions

• Whether Kyrgyzstan's government will respond with regulatory action against

the designated banks/platforms or continue to tolerate their use as sanctions-evasion rails.

• Whether the 100 newly listed vessels overlap with the EU/UK shadow-fleet

lists already in the register, or represent a distinct tranche — worth a cross-reference pass once IMO numbers are available in a structured form.