On December 15, 2025, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the Regulations). These amendments list an additional 4 individuals under Schedule 1 of the Regulations and took effect on December 12, 2025. All of the newly listed individuals are Iranian senior officials who are stated to have been involved in human rights violations and the facilitation of repressive policies within the Islamic Republic of Iran. The Regulations impose a dealings…
Global Affairs Canada (GAC) recently released the first formal guidance (Guidance) on compliance with and enforcement of Canada’s economic sanctions regime. This Guidance was issued alongside further updates to GAC’s Frequently Asked Questions. While the Canadian business community has long awaited formal guidance, many interpretive issues remain unresolved. Background Amendments to Canada’s Special Economic Measures Act (SEMA) and Justice for Victims of Corrupt Foreign Officials Act were adopted in 2022 and 2023, which introduced an…
Global Affairs Canada recently issued Notice to Exporters No. 1159 codifying its longstanding positions on controlled technology and Cloud computing. Historically, Canadian exporters have relied on Advisory Opinions to confirm the application of Canada’s export controls to Cloud computing and while this Notice provides long overdue public guidance on this issue, substantive guidance on SasS is noticeably absent. What Exporters Need to Know The Guidance A key issue facing Technology Holders relying on the Cloud…
On November 12, 2025, Canada announced further amendments to the Special Economic Measures (Russia) Regulations (the Regulations). These amendments list an additional 13 individuals and 11 entities under Schedule 1 of the Regulations and took effect on November 6, 2025. These newly listed entities and individuals are stated to enable Russia’s energy sector and hybrid warfare strategies, including suppliers of cyber infrastructure and companies linked to liquefied natural gas operations that help finance military activities.…