Global Affairs Canada (GAC) published new guidance clarifying the application of the deemed ownership provisions under Canada’s economic sanctions legislation. The guidance, updated on 13 October 2026, addresses the thresholds for establishing control over an entity, including through aggregated ownership by multiple designated persons, board appointment rights and the exercise of influence. It also provides illustrative scenarios involving indirect ownership structures and potential proxies for designated persons. Background Canada’s deemed ownership provisions were introduced into…
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…
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.…