Global Affairs Canada’s Sanctions Operations, 2018-2024 – Evaluation Summary

About the evaluation

Global Affairs Canada (GAC)’s Evaluation Division conducted an evaluation of GAC’s sanctions operations from 2018 up to and including part of 2024. The evaluation aimed to provide information to support evidence-based decision-making for the expanded Sanctions Bureau; contribute to the review that will be required in 2024-25 related to the Bureau’s funding; and assist with overall learning and program improvement.

Key findings

• The significant increase in sanctions regulations following Russia’s February 2022 invasion of Ukraine highlighted the tensions between sanctions as a domestic regulatory program, and a foreign policy tool.
• Although GAC has lacked a regulatory culture, the Sanctions Policy and Operations Coordination Division (now Sanctions Bureau) has begun to grow into its regulatory role, improving operational capacity by:
  • coordinating within GAC to manage the large increase in sanctions
  • increasing policy coherence around sanctions development and compliance
  • improving coordination with other government departments
  • expanding outreach activities after the limitations of COVID-19
  • managed a large increase in permit and delisting applications
• However, the urgency and frequency of new sanctions packages created legal risks and exceeded GAC’s capacity to manage the operational consequences, including:
  • maintaining standard regulatory practices
  • conducting research in support of listings
  • publishing comprehensive interpretive guidance as required
  • responding to increased permit and delisting requests in a timely manner
• Operational limitations weakened Canada’s sanctions regime in terms of compliance and enforcement and increased the likelihood of unintended impacts on Canadians.

Recommendations

1. Formalize and publish comprehensive written guidance for the public and private sector.
2. Prioritize strategies to improve the efficiency of permit application processing.
3. The Sanctions Bureau should work with GAC’s new Pan-geographic Affairs Branch (GFM) to develop an action plan to ensure that geographic desks are effectively supported.
4. Strengthen the strategic policy role of the Sanctions Bureau.
5. Consider undertaking a comprehensive review, which could take the form of a department-led legislative review.