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Sanctions Regimes

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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 21 November 2025, Singapore’s Ministry of Foreign Affairs announced the imposition of targeted financial sanctions and entry bans against four (4) Israeli settlers for their involvement in acts of violence against Palestinians in the West Bank. On the same day, the Monetary Authority of Singapore (MAS) issued a notice setting out the sanctions measures and details of these designated individuals. Pursuant to the notice, Singapore financial institutions are prohibited from, directly or indirectly, establishing…

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.…

The Office of Foreign Assets Control (“OFAC”) designated Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Public Joint-Stock Company Oil Company Lukoil (“Lukoil”) on October 22, 2025, in response to the ongoing war in Ukraine.  In announcing the designations under Executive Order (“EO”) 14024, Secretary of the Treasury Scott Bessent stated that the actions were taken to advance the administration’s goal of ending the war in Ukraine by targeting two of Russia’s largest oil…