On June 21, 2024, Canada announced further amendments to the Special Economic Measures (Haiti) Regulations (the “Regulations”). These amendments list an additional 3 individuals under Schedule 1 of the Regulations. The amendments took effect on June 20, 2024.

The Schedule 1 sanctions target individuals that Canada has identified as gang leaders whom have undermined the peace, security and stability of Haiti and that have contributed to acts of gross and systematic human rights violations.

The amended Regulations impose a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:

  • dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
  • entering into or facilitating any transaction related to a dealing in a designated person’s property;
  • providing any financial or related services in respect of a dealing in a designated person’s property;
  • making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
  • transferring or providing any property other than goods to a listed person or to a person outside Canada who is not Canadian for the benefit of a designated person; or
  • providing any financial or related services to or for the benefit of a designated person.

Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.

Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property held by Schedule 1 parties and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property of Schedule 1 parties.

An unofficial copy of the legislative amendments to the Special Economic Measures (Haiti) Regulations that came into effect on June 20, 2024 is available on Global Affairs Canada’s website here.

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Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.

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