The Sanctions Bureau at Global Affairs Canada (GAC) recently released guidance, including sector-specific guidance, to assist individuals, businesses, and entities in Canada, as well as Canadians abroad, in ensuring sanctions-related compliance and in mitigating the risks of sanctions violations.
Background
The GAC’s guidance follows on expanding Canadian sanctions measures implemented in response to the evolving global landscape – in particular, Russia’s invasion of Ukraine. It also responds to recommendations for such guidance, including as set out in a January 2024 Report of the Standing Committee on Foreign Affairs and International Development, which considered the transparency, accountability, and effectiveness of Canada’s sanctions regime. Unlike in the U.S. and the U.K., until now, Canada has lacked formal sanctions guidance beyond information provided on the GAC’s “FAQ” webpage.
Key Aspects of the Sanctions Guidance
The guidance:
Provides essential information on Canada’s sanctions regime (e.g., about legislation, measures, exceptions, etc.).
Sets out due diligence and best practices for implementing internal compliance programs (e.g., verifying information, consulting sanctions lists and regulations, considering red flags, recording, and reporting suspicious transactions).
Identifies red flags for detecting suspicious transactions (e.g., designated person links, dual use/high-risk goods, financial and corporate patterns, and structures).
Provides various scenarios, with a view to supporting an understanding of the application of sanctions compliance requirements to transactions and activities.
Tailored guidance for the following sectors has also been published:
When sanctions are implemented, they place limitations on transactions and activities that can be conducted with sanctioned countries or listed individuals and entities. We encourage stakeholders to review the guidance in detail, as the consequences for contravention could be significant. It is also important to monitor sanctions compliance on an ongoing basis.
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