When European exporters think about sanctions on Russia, the frameworks that come to mind first are usually the EU, the United States and the United Kingdom. Canada and Australia rarely feature in the same conversation — and yet both countries operate their own independent sanctions regimes that are actively enforced, continuously expanding, and capable of affecting exporters who have no obvious connection to either country.
This post explains why Canada and Australia belong in the same discussion, what their export restrictions on Russia actually cover, and what exporters need to know to stay on the right side of both frameworks.
Before going further, it is important to be clear about what this post does not cover. Both the Canadian and Australian sanctions regimes are broad, and the majority of their provisions fall outside the scope of what is relevant to exporters of goods. The following are therefore deliberately excluded from this guide:
- Sanctions against specific individuals, oligarchs or Russian entities
- Banking and financial sanctions
- Import restrictions on Russian-origin goods
- Port access restrictions for Russian-flagged vessels
- Travel bans
What remains — and what this post focuses on exclusively — is the prohibition on exporting certain goods from Canada and Australia to Russia.
Why Canada and Australia in the Same Post?
At first glance, Canada and Australia may seem an unlikely pairing for a post about Russia sanctions. They are geographically distant from each other and from Russia, and they rarely feature together in conversations about export controls. But look more closely and the similarities become striking.
Both are advanced liberal democracies, both are members of the Commonwealth, and both are part of the Five Eyes intelligence alliance alongside the United States, the United Kingdom and New Zealand. Both are G20 economies with sophisticated industrial and technology sectors — precisely the profile of exporter that these sanctions are designed to affect. Both responded to Russia’s invasion of Ukraine within days of the February 2022 escalation, and both have consistently expanded their measures in close coordination with the US, UK and EU in the years since.
Perhaps most importantly for exporters, both operate autonomous sanctions frameworks — regimes that are legally independent from the United Nations and the European Union and based on their own national legislation. This means their restrictions can reach exporters who do not have direct Canadian or Australian connections but whose supply chains, subsidiaries or technology licensing arrangements create a link to either jurisdiction.
The practical result is that any thorough sanctions compliance exercise for Russia must include Canada and Australia alongside the more familiar EU, US and UK frameworks. Checking only the well-known regimes while ignoring these two is an increasingly risky oversight.
The Canadian Framework: SEMA and How It Works
The legal foundation of Canada’s sanctions against Russia is the Special Economic Measures Act (SEMA), a 1992 statute that gives the federal government authority to impose autonomous sanctions in response to breaches of international peace and security or serious violations of international law. The Russia-specific measures are implemented through the Special Economic Measures (Russia) Regulations, administered by Global Affairs Canada through its Sanctions Bureau.
Canada first applied sanctions to Russia in 2014 following the annexation of Crimea, and has amended the Russia Regulations more than forty times since February 2022. As of March 2026, the consolidated regulation is the authoritative reference for determining whether a given export to Russia is prohibited.
One structural feature of the Canadian regime that exporters must understand from the outset: the sanctions apply not only to persons physically in Canada but to Canadian citizens and entities wherever they are in the world. This extraterritorial reach means that a Canadian national working for a European company, or a Canadian-incorporated entity operating from within the EU, remains bound by these rules.
The key export restrictions for goods exporters are:
Schedule 7 — Industrial Goods is the list that most directly affects general industrial exporters. It covers a broad range of machinery, electronic components, equipment and tools whose export to Russia is prohibited. In scope and ambition it is comparable to Annex XXIII of the EU’s Regulation 833/2014 — the largest and most wide-ranging list in the EU framework. Any company exporting industrial machinery, sensors, motors, precision components or electronic goods to Russia should verify their HS codes against Schedule 7 before proceeding.
The Restricted Goods and Technologies List (RGTL) covers dual-use goods and strategic technology with potential military or proliferation applications. Global Affairs Canada has not issued export permits for any goods on the RGTL destined for Russia since February 2022.
Chemical and Biological Weapons-related goods, added in July 2025, prohibit the export of a range of chemical precursors and substances including acetone, arsenic, carbon monoxide, isopropanol and mercury. This is a strict prohibition with a narrow set of exceptions — primarily for goods used in support of nuclear safeguard verifications or to prevent imminent risks to human health.
Jet fuel and additives, added in June 2025 and in force from August 2025, prohibit the export of spirit-type jet fuel, kerosene-type jet fuel, and blended aviation fuels including those mixed with biodiesel.
Canada: Key Developments 2025–2026
The Canadian sanctions regime has evolved significantly over the past twelve months, and several developments are directly relevant for exporters.
February 2025 saw the entry into force of the Special Economic Measures Permit Authorization Order, which gives the Minister of Foreign Affairs a new general authority to issue both individual and general permits in exceptional circumstances for activities that would otherwise be prohibited. This is not an opening of the door to ordinary exports — it is a narrow carve-out for genuinely exceptional cases — but it creates a formal permit pathway that did not previously exist in this form.
June 2025 brought what Canadian officials described as one of the most significant sanctions packages against Russia since the full-scale invasion began. Three separate regulatory amendments came into force simultaneously on 13 June 2025, adding new export prohibitions on jet fuel, chemical and biological weapons-related goods, and further expanding the scope of existing restrictions. This package also added 77 individuals, 39 entities and 201 vessels to the shadow fleet designation list, reinforcing the message that enforcement is expanding alongside the substantive restrictions.
August 2025 was the date on which the new import prohibitions and the jet fuel export ban came into full force, following the wind-down periods provided in the June 2025 amendments.
November 2025 brought a further round of additions, including entities linked to drone development and two Russian LNG companies, as well as 100 additional shadow fleet vessels.
February 2026 marked the fourth anniversary of the invasion. Canada announced a further expansion of its sanctions, with new entity listings focused on Russia’s military and hybrid-warfare infrastructure. Notably, Global Affairs Canada simultaneously published updated guidance on the application of the sanctions, introducing a broader interpretation of what constitutes ownership and control under the SEMA framework — with implications for how compliance officers assess indirect exposure.
One development that stands apart from the regulatory timeline is the first criminal prosecution under Canada’s Russia sanctions regime. In May 2025, the RCMP arrested a Canadian businessman and charged him with exporting banned microelectronics to Russia through intermediary countries. The goods were allegedly components used in Orlan-10 drones deployed by Russian forces in Ukraine. The case is the first of its kind under the Russia Regulations and is being closely watched by the compliance community as it will establish key precedents on intent, evidence and enforcement.
The Australian Framework: The Autonomous Sanctions Act
Australia’s export restrictions on Russia operate under the Autonomous Sanctions Act 2011 and the Autonomous Sanctions Regulations 2011, administered by the Australian Sanctions Office (ASO) within the Department of Foreign Affairs and Trade (DFAT). Australia first applied autonomous sanctions to Russia in 2014 and has extended them significantly in 2022, 2023 and 2025.
The Australian regime applies to Australian citizens and entities wherever they are located, as well as to any person or entity within Australia, on Australian ships or aircraft, or whose conduct produces effects in Australia. Like Canada, this creates an extraterritorial dimension that can reach non-Australian companies through their Australian connections.
One feature of the Australian framework that deserves particular attention is its strict liability standard for corporate offences. Under Australian sanctions law, it is not necessary to prove that a company intended to violate the sanctions — the act of violation is sufficient for liability. The only available defence is demonstrating that the company took reasonable precautions and exercised due diligence to avoid the contravention. The penalties are substantial: up to ten years’ imprisonment for individuals, or up to AUD 2.22 million — or three times the value of the transaction — for corporate entities.
The key export restrictions for goods exporters are:
The Export Machinery Ban, introduced in October 2023, is the cornerstone export restriction for industrial goods exporters. It designated a wide range of industrial and electrical machinery, equipment, tools, pumps and boilers as export sanctioned goods for Russia. In practical terms, this is the Australian counterpart to the EU’s Annex XXIII — a broad, catch-all prohibition on industrial goods that goes well beyond the narrow strategic sectors restricted before 2022. Any exporter of machinery, industrial components or electrical equipment must check whether their AHECC codes fall within the scope of this designation.
Luxury goods were designated as export sanctioned goods from 2022, covering high-value items destined for the Russian market above defined thresholds.
Aluminium ores, alumina and related products have been subject to export restrictions since 2022 under the Autonomous Sanctions (Export Sanctioned Goods – Russia) Designation 2022.
Unmanned aircraft (drones) and drone components — AHECC headings 8806 and 8807 — were added as export sanctioned goods in February 2025, reflecting the recognised role of commercial drone technology in the conflict.
A supply of export sanctioned goods to Russia requires a permit from the Minister for Foreign Affairs, which is only granted where specific criteria are met. In practice, the threshold is high and approvals for ordinary commercial exports to Russia are not forthcoming.
Australia: Key Developments 2025–2026
February 2025 brought the most significant expansion of Australia’s export controls since the 2023 Export Machinery Ban. Drones and drone components were designated as export sanctioned goods for Russia and specified Ukrainian regions occupied by Russia, reflecting the international consensus on the military application of this product category.
September 2025 saw Australia lower its oil price cap on Russian crude oil to USD 47.60 per barrel, aligning more closely with the trajectory set by the G7 partners and tightening the squeeze on Russian energy revenues.
February 2026, on the fourth anniversary of the invasion, Australia lowered the oil price cap further to USD 44.10 per barrel. The Australian Sanctions Office simultaneously updated its guidance on the import, purchase and transport of Russian-origin petroleum products, providing new clarifications on de minimis quantities and third-country transformation — primarily relevant for shipping and logistics operators rather than goods exporters, but indicative of the continued regulatory attention being paid to sanctions circumvention routes.
How Canada and Australia Compare — and How They Fit into the Broader Picture
| Canada | Australia | |
|---|---|---|
| Legal basis | Special Economic Measures Act 1992 | Autonomous Sanctions Act 2011 |
| Administrator | Global Affairs Canada — Sanctions Bureau | Australian Sanctions Office (DFAT) |
| Extraterritorial reach | Canadians worldwide | Australians worldwide + persons in Australia |
| Corporate liability | Intent required for individuals | Strict liability for companies |
| Key export restriction list | Schedule 7 + RGTL + specific designations | Export Machinery Ban + specific designations |
| Drone ban | Via RGTL and Schedule 7 | Explicit (Feb 2025, AHECC 8806/8807) |
| Chemical/bio goods | Explicit ban from July 2025 | Via Export Machinery Ban scope |
| Coordination | G7, Five Eyes, aligned with US/UK/EU | Five Eyes, G20, aligned with US/UK/EU |
Neither Canada nor Australia applies the US Foreign Direct Product Rule — the mechanism that extends US jurisdiction to products made outside the United States using American technology. However, their frameworks are independent and active, and a European exporter with Canadian or Australian connections in its supply chain, ownership structure or licensing arrangements may well find itself within scope.
The Five Eyes and G7 coordination frameworks mean that the lists of restricted goods tend to expand in parallel across all five Western regimes. What gets added to the EU’s Annex XXIII or the US EAR supplements typically finds its way into Canada’s Schedule 7 and Australia’s export sanctioned goods designations within months. Checking only the most familiar regime and assuming the others will follow is a reasonable proxy — but it is not a substitute for verification.
A Practical Checklist for Exporters
Before proceeding with any export to Russia where Canadian or Australian connections may be relevant, work through the following:
- Assess your connections to both jurisdictions. Does your company have Canadian or Australian shareholders, directors, employees or subsidiaries? Does your supply chain include components of Canadian or Australian origin? Does your technology licensing include Canadian or Australian-owned intellectual property? Any of these may bring you within scope.
- Check the Canadian Schedule 7 and the Australian Export Machinery Ban if you export industrial machinery, electrical components, tools, motors, sensors or related goods. These are the broadest and most practically significant export restrictions in both frameworks.
- Check the Canadian RGTL if your product has any dual-use or technology dimensions. No export permits for RGTL items to Russia have been issued since February 2022.
- Check the Australian AHECC designation lists against your product codes. The Australian Sanctions Office publishes guidance notes and an AHECC reference table for export sanctioned goods.
- Verify your buyer and any intermediaries against the Canadian Global Affairs Canada designated persons list and the Australian ASO designation list, separately from the EU and US lists.
- Verify payment routes before accepting any order. The de-risking behaviour of international banks applies to transactions involving Canadian and Australian sanctions exposure just as it does for EU and US sanctions.
- If your product is permitted under all applicable regimes, ensure your EAC certification is current and valid before shipping. A clean sanctions compliance record does not substitute for missing customs documentation at the EAEU border.
Conclusion
Canada and Australia are not the most visible names in the Russia sanctions landscape, but they are active, coordinated and increasingly consequential. Both frameworks have expanded significantly since 2022, both are enforced — Canada’s first criminal prosecution under its Russia sanctions regime in 2025 is a clear signal of the direction of travel — and both operate with extraterritorial reach that can catch non-Canadian and non-Australian companies off guard.
For any company with exposure to either jurisdiction — whether through ownership, supply chain, technology licensing or the nationality of key personnel — checking only the EU, US and UK frameworks is not sufficient. The full picture requires all five, and in a world where Five Eyes coordination continues to tighten, the gap between the regimes is narrowing with every new package.