First charges laid under Canada’s Russia sanctions – what does this mean for further enforcement and judicial guidance? First charges laid under Canada’s Russia sanctions – what does this mean for further enforcement and judicial guidance?

On May 28, 2025, the Royal Canadian Mounted Police (RCMP) announced the first charges for alleged violations of Canada’s sanctions against Russia, which have been massively expanded since Russia’s invasion of Ukraine in 2022. Anton Trofimov, a Russian national and resident of Canada, was charged with two counts of violating the Special Economic Measures Act (SEMA) and one count of violating the Canadian Criminal Code.

While Canada has an extensive array of sanctions measures in force, prosecutions under Canadian sanctions laws have been rare. The charges against Mr. Trofimov, therefore, have prompted speculation that Canada may be increasing its efforts to enforce its sanctions, including those on Russia. However, we remain skeptical. The charges seem to target low-hanging fruit rather than suggesting newfound ambition or sophistication in Canada’s sanctions enforcement efforts.

The ‘low-hanging fruit’

Sanctions violations can be challenging to prosecute; investigations can require complicated forensic analyses into financial transactions, and criminals have developed elaborate evasion tactics. However, the allegations against Mr. Trofimov suggest more blatant conduct. He is charged with having exported, sold, supplied or shipped prohibited goods (specifically, microelectronics identified as components for Orlan-10 drones) to Russia or persons in Russia between July 17, 2022, and December 8, 2022, in contravention of the Special Economic Measures (Russia) Regulations. Mr. Trofimov is also charged with knowingly possessing proceeds of crime, in contravention of the Criminal Code.

Moreover, Mr. Trofimov and entities associated with him have been identified since at least 2023 as being involved in sanctionable activities or sanctions violations. He and a Toronto-based company linked to him (10219452 Canada Incorporated) were sanctioned by the United States two years ago, in May 2023. Another entity connected to Mr. Trofimov — Asia Pacific Links Limited — has been sanctioned by nearly a dozen jurisdictions (including the European Union) for being one of the largest suppliers of components of Orlan drones to the Russian military since the beginning of the war in Ukraine in 2022. The Canadian government was specifically advised of Mr. Trofimov’s activities in February 2023, in a brief provided by the Ukrainian Canadian Congress, and Mr. Trofimov was mentioned by officials from Global Affairs Canada in testimony to a parliamentary committee that same year.

Business should not expect much clarity from Trofimov case

The lack of enforcement of Canadian sanctions laws has meant that courts have had almost no opportunity to interpret those laws or the regulations under them, or to address their considerable ambiguities, including those identified in our previous Update. These ambiguities include the scope of the anti-facilitation provisions in regulations under the SEMA and the criteria in the SEMA for establishing “deemed ownership” by sanctioned persons. As we’ve explained, guidance from Global Affairs Canada has been of limited assistance.

However, even if the Trofimov case proceeds to trial, the nature of the facts alleged — the sale of goods expressly prohibited for export to Russia — makes it unlikely that the court will be required to address the interpretive uncertainties that have frustrated businesses trying to comply with Canadian sanctions laws.

In short, the charges against Mr. Trofimov leave unanswered the question of whether the Canadian government is committed to and capable of prosecuting more complex cases of sanctions evasion, including related financial crimes. They also are unlikely to produce answers to the many interpretive questions in the SEMA and other Canadian sanctions laws with which businesses routinely struggle.