A Russian expatriate with a Canadian-registered company has been charged by the RCMP under both the Special Economic Measures (Russia) Regulations (“Russia Regulations”) and the anti-money laundering provisions of the Criminal Code. This is the first prosecution for alleged violations of Canada’s economic sanctions against Russia since Russia’s illegal invasion of Ukraine in February 2022. In fact, these are the first sanctions-related charges brought by the RCMP in over 10 years, despite the significant expansion of Canada’s sanctions regime over that period, which now prohibits dealings with over 4,500 individuals and entities in over 20 countries.
Background
Mr. Anton Trofimov is alleged to have exported, sold, supplied, or shipped goods to Russia or a person in Russia, contrary to the Russia Regulations, between July 17, 2022 and December 8, 2022. He has also been charged with one count of knowingly possessing proceeds of crime contrary to section 354(1) of the Criminal Code.
The charges were laid more than two years after Mr. Trofimov and his company, Asia Pacific Links Ltd., were added to the Specially Designated Nationals list maintained by the Office of Foreign Assets Control (“OFAC”) of the United States Treasury Department. At that time, it was reported that OFAC believed Mr. Trofimov was part of the procurement network working to obtain technology for Russian Orlan-10 drones. It is not yet clear whether the charges laid by the RCMP stem from this two-year old allegation.
The charges against Mr. Trofimov come amid a period of significant expansion of Canadian sanctions. Since February 2022, the number of individuals and entities listed under the various regulations of the Special Economic Measures Act (“SEMA”) has tripled, to more than 4,500. Those targeted under the Russia Regulations have seen the greatest growth. Despite this expanded scope, the charges against Mr. Trofimov are the first to be laid with respect to Russia Regulations violations since Russia’s invasion of Ukraine three years ago.
Enforcement: Key Takeaways
Given the historic dearth of prosecutions of Canadian sanctions breaches, these recent charges shed much-needed light on the enforcement process. Key takeaways include:
- Russia Focus. Unsurprisingly, the first sanctions-related charges brought by the RCMP in over 10 years involve the Russia Regulations. Over half of all individuals designated under Canada’s unilateral sanctions regime are listed under the Russia Regulations. This fact, coupled with the government’s longstanding strong support of Ukraine, made it likely that the RCMP would focus its enforcement of SEMA, specifically on breaches of the Russia Regulations.
- Timing. The alleged activities of Mr. Trofimov occurred in the second half of 2022, and yet the RCMP did not bring charges until May 2025. Given that OFAC made similar (or even identical) allegations in May 2023, and concerns about Mr. Trofimov were raised when a Global Affairs Canada witness appeared before the House of Commons Standing Committee on Foreign Affairs and International Development that month as well, Global Affairs Canada must have been aware of the alleged dealings. The delay between the alleged conduct and the charges being laid serves as a reminder that the RCMP may still be working its way through cases from over three years ago and that similar charges could follow.
- Industry Focus. It has been reported that Mr. Trofimov is facing charges for breaching sections 3.06(1) and 3.09(1) of the Russia Regulations which prohibit the export, sale, supply, and shipment of specific goods to any person in Russia. While the details surrounding Mr. Trofimov’s alleged activity are limited, if the charges stem from the same activity identified by OFAC, it is noteworthy that the RCMP is pursuing charges likely related to the electronics and drone industries. The circumvention of Canadian sanctions in the electronics space has been widely reported, so it will be interesting to see whether this focus continues or whether we may see charges laid related to other industries.
- Sanctions and Anti-Money Laundering. The charges also include one count of violating section 354(1) of the Criminal Code, which prohibits the possession of the proceeds of crime. While we do not yet have details on this particular count, it underscores that the RCMP will use all the tools in its toolkit to seek to punish and deter wrongdoing.
- OFAC Designated Individual. OFAC has listed both Mr. Trofimov and companies associated with him on their SDN list for over two years. This raises interesting questions about the RCMP’s investigation timeline as well as the possibility that other Canadians and Canadian residents similarly targeted by OFAC may eventually face charges laid by the RCMP.
Global News was first to report on these charges, and we await further details from the RCMP. We will update this blog post as we learn additional information about the allegations.
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