On April 15, 2024, Canada announced new sanctions regulations under the Special Economic Measures Act in response to gross and systematic violations of human rights. The Special Economic Measures (Sudan) Regulations (the “Regulations”) designate six individuals and entities and entered into force on April 12, 2024.
The Regulations were announced on the one-year mark of the ongoing conflict between the Sudanese Armed Forced (SAF) and the Rapid Support Forces (RSF) in Sudan, who are fighting for control of Sudan’s major institutions. The conflict has displaced millions of Sudanese people and has directly killed at least 14,700 people in Sudan.[1]
The individuals and entities targeted have directly or indirectly undermined peace, security and stability in Sudan and are associated with the SAF and RSF. For example, one high-profile sanctioned individual is Abdelrahim Hamdan Dagalo, a high-ranking leader of the RSF and brother of RSF Commander Lieutenant General Mohamed Hamdan Dagalo. One entity targeted is Al Junaid Multi Activities Co Ltd, a Sudanese holding company controlled by Mohamed Hamdan Dagalo and his brother. Defense Industries System, which manufactures military weapons and equipment, is also designated.
The Regulations build on Canada’s current sanctions related to Sudan imposed under the United Nations Act. Similar sanctions measures have been implemented by Canada’s international partners, including the EU, UK and US.
The Regulations impose a dealings prohibition against the individuals listed, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
(a) dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
(b) entering into or facilitating any transaction related to a dealing in a designated person’s property;
(c) providing any financial or related services in respect of a dealing in a designated person’s property;
(d) making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
(e) 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
(f) providing any financial or related services to or for the benefit of a designated person
Note that “control” under the dealings prohibition is governed by the broad deeming provision implemented under the Special Economic Measures Act in June 2023.
Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.
An unofficial copy of the Special Economic Measures (Sudan) Regulations, which came into effect on April 12, 2024 is available on Global Affairs Canada’s website here. An unofficial copy of the Special Economic Measures (Sudan) Permit Authorization Order, which authorizes the Minister of Foreign Affairs to issue permits to carry out an otherwise prohibited activity under the new Regulations, is available on the Global Affairs Canada website here.
[1] International Rescue Committee, Sudan Crisis Report: One Year of Conflict.
