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Canada’s Fight against Foreign Bribery - Twenty-sixth Annual Report to Parliament

Implementation of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the Enforcement of the Corruption of Foreign Public Officials Act

(September 2024 – August 2025)

Table of contents

Highlights – September 2024 to August 2025

Background

On December 17, 1997, Canada signed the OECD Convention,Footnote i and Parliament passed the CFPOA to implement Canada’s obligations under the OECD Convention into Canadian law.Footnote ii With the adoption of the CFPOA, which received Royal Assent on December 10, 1998, the Government of Canada deposited its instrument of ratification with the OECD on December 17, 1998, thereby becoming a State Party to the OECD Convention and triggering its coming into force on February 15, 1999.Footnote iii Canada’s CFPOA came into force on February 14, 1999.

The OECD Convention

The OECD Convention aims to stop the flow of bribes and remove bribery as a non-tariff barrier to trade, producing a level playing field in international business. At present, there are 46 States Parties to the OECD Convention, including all 38 member states of the OECD and eight non-member states: Argentina, Brazil, Bulgaria, Croatia, Peru, Romania, Russia,Footnote iv and South Africa.Footnote v Since the OECD Convention entered into force, 687 individuals and 264 entities have been convicted or criminally sanctioned for foreign bribery, and 76 individuals and 109 entities have been convicted or criminally sanctioned for related offences (false accounting or money laundering). Furthermore, 88 individuals and 121 entities have received sanctions for foreign bribery through administrative or civil proceedings, and 76 individuals and 192 entities have received sanctions for related offences (false accounting or money laundering) through administrative or civil proceedings. Based on the most recent enforcement data published in December 2022, 481 investigations are ongoing in 35 States Parties, and 180 prosecutions are ongoing in 12 States Parties relating to offences under the OECD Convention.Footnote vi

Companion instruments

The OECD Convention is supplemented by a number of companion instruments:

The 2009 Recommendation—The OECD Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions (2009 Recommendation)Footnote vii was adopted by the OECD CouncilFootnote viii on November 26, 2009, and released on December 9, 2009, on the tenth anniversary of the OECD Convention. The 2009 Recommendation aims to strengthen for preventing, detecting and investigating foreign bribery.

The 2021 Recommendation—In 2018, the WGB began a comprehensive review of the 2009 Anti-Bribery Recommendation to ensure that it continues to reflect the range of good practices and addresses current challenges. After rigorous assessment and discussions of the 2009 Recommendation, including two rounds of extensive consultations with external partners, the 2021 Anti-Bribery Recommendation (2021 Recommendation) was adopted by the OECD Council on November 26, 2021.Footnote ix

The 2021 Recommendation committed States Parties to the OECD Convention to take new measures to reinforce efforts to prevent, detect, and investigate foreign bribery. The 2021 Recommendation includes new sections on key topics that have emerged or significantly evolved in the anti-corruption area. This includes strengthening the enforcement of foreign bribery laws, addressing the demand side of foreign bribery, enhancing international cooperation, introducing principles on the use of non-trial resolutions in foreign bribery cases, incentivizing anti-corruption compliance by companies, and providing comprehensive and effective protection for reporting persons.

Guidelines for Multinational Enterprises—The OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (the Guidelines) are government-endorsed recommendations encouraging positive economic, environmental, and social contributions while minimizing adverse impacts in corporate operations, products, and services. Last updated in June 2023, the Guidelines include a chapter with recommendations to enterprises on combating bribery and other forms of corruption. The Guidelines recommend that enterprises should have measures in place to prevent, detect, and address bribery and other forms of corruption, including through their business relationships. Countries adhering to the Guidelines are required to maintain National Contact Points (NCPs) to promote the Guidelines and to help resolve disputes about the observance of the Guidelines by multinational enterprises. Canada’s NCP can review instances of alleged non-observance of the Guidelines by multinational enterprises operating in or from Canada and offer its good offices to help parties resolve issues through facilitated dialogue or mediation.

Other companion instruments include the OECD Recommendation on Tax Measures for Further Combating Bribery of Foreign Public Officials in International Business Transactions,Footnote x the Convention on Mutual Administrative Assistance in Tax Matters,Footnote xi the OECD Recommendation on Bribery and Officially Supported Export Credits,Footnote xii and the Recommendation on Anti-Corruption Proposals for Bilateral Aid and Procurement.Footnote xiii

Mandatory peer monitoring process

The OECD Convention provides for mandatory peer evaluation of the implementation and enforcement of the OECD Convention, the 2021 Recommendation, and related instruments. The peer evaluations are carried out by the WGB, of which Canada is a founding member, and which is comprised of representatives from the States Parties to the OECD Convention.Footnote xiv The purpose of ongoing mutual evaluations of the implementation of the OECD Convention and the 2021 Recommendation is to maintain an up-to-date assessment of the structures in place to enforce related laws, rules, and their application in practice.

The peer review monitoring system has been carried out in four phases. Phase 1 is designed to evaluate whether the legal frameworks through which participants implement the OECD Convention meet the standards set by it.Footnote xv Phase 2 studies and assesses the structures put into place to enforce national laws and determine their practical application.Footnote xvi Phase 3 is intended to concentrate on progress made by the States Parties on the recommendations made during Phase 2, on issues raised by changes in domestic legislation or institutional frameworks of the States Parties, and on enforcement efforts, results and other horizontal issues.Footnote xvii Phase 4 was launched in March 2016. In addition to focusing on key horizontal issues, it also endeavours to take a tailor-made approach, considering each country’s unique situation and challenges, progress made on weaknesses identified in previous phases of evaluation, enforcement efforts, and results, and any issues raised by changes in the domestic legislation or institutional framework of each State Party.

Canada and the peer review process

As a State Party to the OECD Convention, Canada is committed to and actively participates in the peer review mechanism as a lead examiner, evaluated country, and member of the WGB. Canada’s participation includes the following:

Canada as Lead Examiner—Canada, along with France, served as co-lead examiners for the OECD WGB’s Phase 4 evaluation of Belgium, which assessed Belgium’s achievements and challenges in implementing the OECD Convention, as well as its progress in addressing the recommendations from its Phase 3 evaluation in October 2013. As part of the evaluation, the co-lead examiners participated in an on-site visit to Belgium in September 2024, during which they met with representatives of the public and private sectors, media, civil society, and academia. The Phase 4 Report on Belgium was adopted by the OECD WGB at its March 2025 Plenary meeting.

In addition, Canada and the Republic of Korea will continue their work as co-lead examiners for the Phase 4 seven-year additional follow-up review to Australia’s Phase 4 Report, which will build upon the findings and recommendations of the Additional Written Follow-up Report published in January 2023. An oral report on Australia’s progress in implementing the OECD Convention was presented at the March 2025 OECD WGB Plenary meetings.

Canada as Evaluated Country—On October 19, 2023, the OECD WGB published its Phase 4 Report on Canada’s efforts to combat foreign bribery since the Phase 3 Report was released in 2011.

Canada’s Phase 4 evaluation included a questionnaire (completed in April 2023), as well as an on-site visit to Canada from May 29 to June 2, 2023, by co-lead examiners from Austria and New Zealand, together with WGB Secretariat officials. During the on-site visit, which took place in Toronto and Ottawa, the WGB delegation met with representatives from Canada’s public and private sectors, academia, media, legal, and accounting sectors. The formal Phase 4 review took place during the WGB Plenary meetings from October 10 to 13, 2023 at the OECD in Paris, during which the WGB examined, finalized, and approved the findings, recommendations and issues for follow-up for the Report. The Phase 4 Report was adopted on October 12, 2023, and a press release was subsequently published on the OECD website.Footnote xviii

The Report notes that Canada has undertaken important legislative reforms to enhance its foreign bribery framework since 2011, including the Remediation Agreement (RA), a non-trial resolution mechanism introduced in 2018. However, the Report also notes that:

The WGB accordingly recommended that Canada:

The Report also notes several positive developments:

As with all Phase 4 reviews of members of the WGB, the WGB’s recommendations for Canada suggest possible areas to further study potential improvement. Canada continues to examine the Phase 4 Report findings with a view to strengthening efforts to combat foreign bribery. Canada’s two-year written follow-up report on the progress it has made in this regard that was initially scheduled to be delivered in October 2025, i.e. two years after the adoption of its Phase 4 Report, has been postponed and is currently scheduled to take place in March 2026. After a decision by WGB members to hold the upcoming October 2025 WGB Plenary meetings remotely, with only a limited number of items, the proposed agenda for the subsequent December 2025 Plenary meetings consequently includes an increased number of proposed items. As a result, WGB members agreed with the Secretariat’s proposal to postpone Canada’s Phase 4 two-year written follow-up report from October 2025 to March 2026.

The Corruption of Foreign Public Officials Act (CFPOA)

The CFPOA criminalizes the bribery of a foreign public official and the maintenance or destruction of books and records to facilitate or hide the bribing of a foreign public official. The CFPOA and Canada’s Criminal Code also criminalize a conspiracy or attempt to commit those offences, as well as aiding and abetting in committing those offences, a common intention to commit those offences and counselling others to commit those offences. Laundering the proceeds of such offences, as well as the possession of property and proceeds obtained by crime, are also offences under the Criminal Code.Footnote xix

As described below, Canada continues to take significant steps to further deter Canadian companies and persons from paying bribes to foreign public officials in the course of business. As part of these efforts, the Government of Canada has been conducting outreach to enhance awareness and encourage companies to adopt measures that can effectively implement their legal obligations with a zero-tolerance approach to the bribery of foreign public officials.

Investigations and prosecutions

To date, there are currently 17 active investigations; eight convictions; two cases in which charges have been laid, but not yet concluded under the CFPOA; and one RA.

Ongoing Matters:

Damodar Arapakota—On November 12, 2020, charges were laid against Damodar Arapakota with respect to allegations of bribes to a public official from Botswana pursuant to subsection 3(1) of the CFPOA. It is alleged that Mr. Arapakota, a former executive from IMEX Systems Inc., a Canadian company located in Toronto, provided a financial benefit to a Botswanan public official and his family.

An investigation was initiated in October 2018 after the new management of the company self-reported allegations of Mr. Arapakota’s illegal acts to the RCMP. On October 21, 2021, an Ontario Provincial Court Judge committed Mr. Arapakota to trial, and on December 1, 2021, four weeks were set aside for the trial from September 9 to October 7, 2022. In an oral decision rendered on January 16, 2023, the Ontario Superior Court of Justice found that, based on the evidence presented, the Crown had failed to prove Mr. Arapakota’s guilt on the foreign bribery charges under section 3(1)(a) of the CFPOA beyond a reasonable doubt. The written decision acquitting Mr. Arapakota followed on March 7, 2023. In May 2023, the Public Prosecution Service of Canada (PPSC) initiated an appeal. The Ontario Court of Appeal heard the appeal in March 2025, and a decision is pending.

Ultra Electronics Forensic Technology Inc. (UEFTI)—On September 20, 2022, Montreal-based company UEFTI and its four former executives were charged with bribery of a foreign public official under sections 3(1)(a) and 3(1)(b) of the CFPOA and section 380(1)(a) of the Criminal Code. It is alleged that the corporation and the accused individuals directed local agents in the Philippines to bribe foreign public officials to influence and expedite a multimillion-dollar contract.

On October 4, 2022, the PPSC filed an application for a RA under Part XXII.1 of the Criminal Code. The PPSC and UEFTI requested an in-court approval hearing that would proceed in camera in order to protect settlement privilege. On November 16, 2022, the Superior Court of Québec released a decision addressing a temporary publication ban in the context of the approval hearing for the RA. The court ordered a temporary publication ban on the contents of the approval hearing in order to protect the fair trial rights of the individuals accused awaiting trial on similar charges against the corporation. The matter remains pending before the court. On May 16, 2023, the Superior Court of Quebec published the details of the four-year RA, including:

On November 22, 2023, Michael McLean pleaded guilty to one count under section 3(1)(a) of the CFPOA. He was sentenced to a 12-month conditional sentence order at that time. On December 5, 2024, following a five-week trial, Timothy Heany was found guilty by a jury of two counts of bribery of foreign public officials under section 3 of the CFPOA. Two co-accused, Robert Walsh and René Bélanger, were acquitted. Mr. Heany was sentenced to a term of imprisonment in the community of two years less one day. Mr. Heany has appealed his conviction, and the Crown is appealing the sentence that was imposed. No hearing date for the appeal has been set.

Canada and the fight against foreign bribery

A number of federal departments, agencies, and Crown corporations play key roles in Canada’s fight against foreign bribery. They work in close cooperation to implement Canada’s three-pronged approach to foreign bribery, which focuses on prevention, detection, and enforcement.

Canada Revenue Agency (CRA)

Exchange of information—The Canada Revenue Agency (CRA) has a large network of international partners, with 94Footnote xx tax treaties and 24 Tax Information Exchange Agreements (TIEAs). Canada is also a State Party to the Convention on Mutual Administrative Assistance in Tax Matters (MAAC), which includes 150 signatories. Combined, the CRA can exchange tax information with a total of 156 jurisdictions. These instruments facilitate the exchange of information to detect and combat tax avoidance and tax evasion, including ways which may deter the bribery of foreign officials. In addition, the CRA is engaged in exchanging non-residents’ financial account information with approximately 100 jurisdictions under the Common Reporting Standard with account holders’ jurisdictions of residence, which results in the CRA receiving financial account information from other jurisdictions in respect of accounts owned by Canadian residents. The CRA may also use mutual legal assistance in criminal matters (MLACM) requests to obtain investigative assistance from a foreign country, even if there is no instrument binding the two countries. However, in this type of request, the foreign state does not have an obligation to assist.

Furthermore, Budget 2023 introduced legislative changes to improve financial intelligence information sharing between Canadian law enforcement and the CRA. One of these changes was an amendment to the Criminal Code to expand the list of offences on the basis of which an examination of information obtained by the Minister of National Revenue under various tax statutes may be authorized. This list now includes bribery and corruption offences (including the bribing of a foreign public official). CRA disclosures of tax information to law enforcement pursuant to this legislation may be made only when they have been judicially ordered.

The CRA may also disclose tax information, pursuant to the Income Tax Act or the Excise Tax Act, to an appropriate police organization when it has reasonable grounds to believe that this information will afford evidence of a listed serious offence, which includes bribery and corruption offences (including the bribing of a foreign public official).

In the case of information provided to the CRA by foreign governments under tax treaties, TIEAs, or the MAAC, the CRA may be prevented from sharing the information or would require the written consent of the sending jurisdiction to share the information.

In addition, the CRA continues to be committed to the exchange of information through specific, spontaneous and automatic exchange mechanisms that facilitate cooperation and tax transparency. This includes engaging with Canada’s treaty partners and collaborating with foreign tax administrations in numerous OECD working groups and bodies, as well as the Global Forum on Transparency and Exchange of Information for Tax Purposes. The CRA remains engaged in numerous capacity-building efforts, such as the OECD’s Global Relations Programme on Taxation and the OECD International Academy for Tax Crime Investigation, which assists other countries in developing their tax administration expertise. The CRA also participates in the OECD’s Task Force on Tax Crime and Other Crimes and is one of five founding members of the Joint Chiefs of Global Tax Enforcement (J5), a multinational group formed in 2018 to increase collaboration in the fight against international and transnational tax crime, and money laundering.

Training and Outreach—The CRA provides an e-learning product to ensure that auditors and investigators are aware of their role in combating corruption as it relates to tax non-compliance and associated legislation. The CRA also conducts outreach activities to make sure that the RCMP is aware of the CRA’s ability to share taxpayer information when it relates to bribery.

Canadian Commercial Corporation (CCC)

The Canadian Commercial Corporation (CCC) is committed to combating bribery and corruption and ensuring that its business activities and the export transactions it supports meet the highest ethical standards. CCC’s anti-corruption and bribery commitments are set out in CCC’s Responsible Business Conduct Framework,Footnote xxi Code of Conduct and Business Ethics for employees,Footnote xxii and client Code for Exporters.Footnote xxiii These policies and their implementing instruments seek to promote a culture of integrity and provide specific direction and guidance to CCC’s leadership, employees, and exporters supported by CCC.

CCC’s leadership, employees and exporters must undertake to uphold the principles of the Code of Conduct and Business Ethics and the Code of Exporters respectively, which include anti-corruption and anti-bribery commitments. Exporters must certify that they will ensure the application of the Code for Exporters in their business activities and operations and report any actual or potential violations to CCC. Further, exporters must certify that they will cooperate in good faith with the NCP for the OECD Guidelines should the company be named in a complaint.

CCC is committed to the continuous improvement of its integrity policies, practices, and procedures. Periodic reviews of the Responsible Business Conduct Framework and related instruments are undertaken to ensure these keep pace with evolving laws, standards, and best practices, including the standards expressed in the OECD Guidelines. CCC also works with Canadian government departments and other Crown corporations to ensure alignment in approaches to integrity and to share best practices.

As part of combating corruption, CCC undertakes transactional due diligence to detect, prevent and mitigate the risks of corruption and bribery throughout the life cycle of a transaction. The Integrity Compliance Committee reviews transactions and exporters to identify and address actual or potential risks relating to bribery and corruption, as well as monitor transactions on an ongoing basis. Where the risks of bribery and corruption are elevated, a transaction is referred to an oversight committee for consideration and may also be referred for enhanced managerial review. The exporter’s integrity policies and training are also reviewed as part of the due diligence. CCC makes recommendations and works collaboratively with exporters to address gaps and strengthen their integrity programs, and to address and mitigate any actual or potential integrity risks in a transaction. CCC may also require an exporter to implement integrity training and policies as a condition to CCC’s support for a project.

CCC assists exporters in implementing its recommendations by providing guidance, advice, resources, information, and training on anti-corruption and anti-bribery, and has provided one-on-one guidance to assist several exporters in successfully implementing and improving their integrity regimes.

To help uphold anti-corruption principles and promote accountability, CCC’s contracts with exporters include standard anti-corruption clauses which give CCC the right to suspend, audit, and terminate a contract in case of violations of these commitments. CCC also provides a reporting mechanism through the disclosure page of its website. Exporters, employees, and third parties are able to submit allegations of wrongdoing and raise any concerns in relation to CCC projects and have the option to do so anonymously.

CCC leverages external resources to enhance its anti-corruption due diligence and improve practices and procedures. As a member of TRACE International, a non-profit international business association dedicated to anti-bribery, compliance, and good governance, CCC is provided access to TRACE International’s integrity training, tools, resources, and support services. CCC requires its employees to take mandatory annual training on responsible business conduct, as well as anti-bribery and anti-corruption.

CCC also facilitates anti-corruption training through TRACE International for exporters who do not have an adequate training program in place. Companies seeking CCC support to export their products and services are generally required to implement appropriate integrity policies and training programs.

To promote awareness of integrity and compliance best practices, CCC recently expanded its offering to provide a one-time TRACE anti-corruption online course to any Canadian company that could benefit from the training. Many exporters and Canadian entities have leveraged this training to enhance their integrity training programs.

Competition Bureau of Canada (CB)

Combating Corruption—There can be a close relationship between collusive behaviour and corruption. Given this possible connection, the Competition Bureau of Canada (CB) continues to maintain and improve its relationships with police forces, procurement authorities, and other organizations to complement each organization’s efforts to promote competition and combat corruption.

The CB continues to receive tips through the Federal Contracting Fraud Tip Line (Tip Line), a joint initiative of the CB, Public Services and Procurement Canada (PSPC), and the RCMP, established in April 2017. A dedicated telephone line (and online form) are available to Canadians to anonymously report suspected fraud, collusion, or corruption in federal government contracts and real property agreements. It complements measures already in place to ensure that federal contracts are lawful, ethical and fair. The information received through the Tip Line may be used to conduct investigations, gather intelligence, and introduce due diligence measures to protect the integrity of federal government contracts and real property agreements.

Although not directly targeted at combating bribery or corruption, the CB developed a tool to fight bid-rigging and help procurement agents minimize factors that increase the risk of collusion. The Collusion Risk Assessment Tool (the Tool) helps procurement agents who draft and administer tender specifications to identify potential collusion and put in place mitigation strategies that promote competition. The Tool is free and web-based. It can be used anonymously by both public and private sector procurement officers and purchasing agents.

Raising Awareness—The Cartels Directorate of the CB continues to prioritize outreach presentations to public procurement organizations at all levels of government. The goal is to provide procurement officials with the information they need to detect, prevent, and report bid-rigging to the CB. These presentations cover topics including:

The CB continues to encourage procurement authorities to require a Certificate of Independent Bid Determination (CIBD) as part of all tenders. Through its signature, the supplier attests that it determined and submitted its bid independently of other competitors. Suppliers include a signed CIBD form as part of their submission package. This encourages ethical decision-making by potential suppliers at the point of bid submission.

Department of Finance Canada (FIN)

The Government of Canada has taken a series of legislative and regulatory measures to further strengthen Canada’s Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) framework.

On January 1, 2025, and March 4, 2025, the Government of Canada published new regulatory amendments to, among other things:

On April 1, 2025, a legislative amendment to the PCMLTFA came into force to allow the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to share financial intelligence with provincial and territorial civil forfeiture offices to support efforts to seize property linked to crime.

On June 3, 2025, the Government of Canada introduced Bill C-2, the Strong Borders Act, which proposes comprehensive amendments to strengthen AML/ATF supervision, compliance, and enforcement, enhance information sharing, and address some of the most prevalent types of money laundering, including to:

Several of the above measures had previously been announced in the 2024 Fall Economic Statement, alongside other measures, such as the Government of Canada’s intention to strengthen enforcement by expanding the application of the AML/ATF framework to include company service providers.

In order to support the accuracy and integrity of Canada’s new federal beneficial ownership registry maintained by Corporations Canada, in March 2025, the Government of Canada announced that, starting October 1, 2025, reporting entities under the PCMLTFA framework will be required to report material discrepancies between their records and their registry filings.Footnote xxiv In the 2025 Ontario Budget, the Government of Ontario announced its intention to initiate consultations to establish a beneficial ownership registry. Québec has already launched a public beneficial ownership registry, and British Columbia has passed legislation to that effect.

The Government of Canada has also taken actions aligned with the AML recommendation pertaining to the coverage of the legal profession set out in the OECD WGB’s Phase 4 Monitoring Report on Canada. Since 2019, the Government of Canada has been collaborating with the Federation of Law Societies of Canada (FLSC) in a joint working group to address the high money laundering vulnerabilities to which the legal profession is exposed, and to enhance information sharing between the Government of Canada and the FLSC. Department of Finance Canada officials are committed to continue to work with the FLSC, the law societies, the Department of Justice Canada and other implicated federal AML/ATF regime partners to manage and mitigate the high money laundering risks that may arise in the practice of law.

Department of Justice Canada (JUS)

Minister of Justice and Attorney General of Canada (AGC)—The Department of Justice (JUS) supports the dual roles of the Minister of Justice and the Attorney General of Canada (AGC). The Department supports the Minister of Justice in their responsibilities for 49 statutes and areas of federal law by ensuring a bilingual and bijural national legal framework principally within the following domains: criminal justice (including youth criminal justice), family justice, access to justice, Aboriginal justice, public law and private international law. The Department also supports the AGC as the chief law officer of the Crown, both in terms of the ongoing operations of government and of the development of new policies, programs and services for Canadians. As chief law officer of the Crown, the AGC oversees federal prosecutions within the framework of the Director of Public Prosecutions Act (DPPA). The DPPA gives primary authority for the initiation and conduct of prosecutions to the Director of Public Prosecutions under and on behalf of the AGC.

International Anti-Corruption Activity—JUS officials participate in international anti-corruption forums, including in meetings of the G7 Anti-Corruption Task Force for Ukraine and the OECD WGB. A member of the WGB Canadian delegation from JUS also participates in the WGB’s Management Group, which supervises the agenda of the WGB and supports the Chair.

Mutual Legal Assistance (MLA)—The International Assistance Group (IAG) is Canada’s central authority for mutual legal assistance (MLA) in criminal matters. Canada has bilateral MLA treaties with 35 countries, pursuant to which Canada can provide formal assistance in criminal matters. Further, Canada is engaging in treaty negotiations with a number of countries with whom a formal or updated treaty would facilitate international cooperation. Additionally, the OECD Convention, the United Nations Convention against Corruption, the Inter-American Convention against Corruption and the Inter-American Convention on Mutual Legal Assistance in Criminal Matters provide Canada with the legal means to provide formal assistance to countries that have signed and ratified those conventions.

The IAG has designated a legal counsel to deal with all incoming and outgoing corruption-related MLA requests. This legal counsel works closely with the RCMP, the PPSC, and other relevant law enforcement officials and prosecutors. Given the ever-increasing number of incoming requests for assistance, the responsibility for corruption-related requests is being shared with other counsel within the IAG, under the supervision of the designated legal counsel, who remains the point of contact for corruption-related requests.

Additionally, the IAG has designated legal counsel to coordinate asset recovery efforts on behalf of Canada. Having this additional point of contact allows Canada to address requests for asset recovery with increased efficiency and effectiveness.

Training and Outreach—The IAG regularly liaises with the central authorities from other countries to facilitate exchanges and educate foreign officials with respect to the Canadian legal requirements to obtain effective assistance in criminal matters. The IAG works closely with foreign officials to assist in drafting MLA and extradition requests, which allows them to make more effective requests to Canada in the fight against corruption. The IAG regularly hosts and attends consultations with foreign authorities to discuss ways to improve the efficiency and effectiveness of the MLA process. For example, the IAG presented to the Asia Pacific Group, a Financial Action Task Force (FATF) regional body, about the use of MLA in “Grand Corruption” cases (i.e., cases of alleged corruption by higher-ranking government officials and elected officials). The IAG has also been establishing ties with the International Anti-Corruption Coordination Centre to provide timely information and advice to officials seeking evidence from Canada.

Moreover, the IAG provides advice and training to Canadian prosecutors and law enforcement and foreign officials regarding the assistance that can be provided without the requirement of a formal request.

In terms of outgoing Canadian requests on corruption matters, the IAG also provides advice and training to Canadian prosecutors and law enforcement officials on the legal requirements for seeking assistance from other countries. For example, in September 2024, the IAG presented to the RCMP about the use of MLA in corruption cases. Additionally, the IAG maintains a website that provides guidance to foreign officials on making MLA requests to Canada and Canadian officials on making MLA requests to foreign jurisdictions. It also maintains a public guide for foreign officials about how to seek MLA from Canada to recover assets.

Of further note, in 2023, amendments to the Mutual Legal Assistance in Criminal Matters Act came into force, allowing Canada to execute MLA requests for the enforcement of foreign orders for the seizure of digital assets.

Canada also participates in capacity-building exercises hosted by international organizations such as the Commonwealth Secretariat, the United Nations Office on Drugs and Crime, and the International Institute for Justice and the Rule of Law. These initiatives are geared towards assisting countries in developing their international cooperation regimes. Canada provides information on the Canadian legal system, including Canada’s approach to dealing with MLA in criminal matters.

Export Development Canada (EDC)

Combating Corruption—Export Development Canada (EDC) continues to allocate resources to reinforce principles of ethical business conduct. EDC is dedicated to anti-bribery and corruption efforts and working with customers who share its commitment to ethical business practices, as set out in the EDC Code of Conduct.

EDC performs the necessary due diligence to ensure that it does not knowingly engage in or support any transaction that involves any form of bribery or corruption.Footnote xxv EDC’s Financial Crime Program outlines measures that EDC applies to combat corruption, including (i) possible notification to law enforcement authorities, and (ii) refusal to provide support where, in EDC’s opinion, there is credible evidence that bribery was involved in a transaction. Further, EDC’s Program consists of processes and documentary safeguards, such as the requirement for customers to submit anti-corruption declarations and/or accept relevant provisions in their contracts, to help ensure that EDC upholds its commitments. EDC conducts corruption risk screening, and where risk indicators are identified, enhanced due diligence is then undertaken by a specialized team. EDC may work with Canadian government departments to ensure alignment in its approach to companies facing corruption-related issues.

In addition, EDC has strengthened its controls, not only as they relate to bribery and corruption, but also as they relate to financial crime risks generally. This is part of EDC’s continuous improvement efforts that reflect evolving best practices, including enhancements related to the collection and monitoring of counterparty information. EDC continues to implement improvements to its enhanced due diligence for higher-risk counterparties and transactions, employee training, program monitoring and oversight, and other controls that support EDC’s ability to detect and deter bribery and corruption among other financial crime risks. EDC prioritizes maintaining alignment with the OECD Recommendation on Bribery and Officially Supported Export Credits.

Raising Awareness—As EDC assists customers in pursuit of international opportunities, it informs them about conducting business in a socially-responsible and ethical manner. This includes providing information, training, and awareness-raising measures to both customers and representatives abroad on:

EDC continues to promote and stay abreast of recent trends in ethical business practices through its attendance at anti-corruption events, such as the Financial Crime Coordination Centre ConferenceFootnote xxvii held by Public Safety Canada. EDC also participates in anti-bribery forums, including collaborations with Transparency International Canada and the OECD Anti-Bribery and Corruption Experts Group. Further, EDC provides customers with information and resources on financial crime risks and EDC’s risk management approach. EDC also reports on its practices related to combating bribery in international business transactions in its corporate annual report.

In this reporting period, EDC outreach included providing exporters continued access to a variety of resources, including EDC’s Anti-Corruption Resources Centre, where they are provided with materials on anti-corruption best practices. EDC also continues its “Trade Insights” email newsletter with links to responsible business conduct materials and continues to host useful blog articles. Through ongoing efforts to educate and promote sound ethical conduct, EDC seeks to support companies as they manage risks in existing operations and as they enter new markets.

Financial Transactions and Reports Analysis Centre of Canada (FINTRAC)

As Canada’s financial intelligence unit, FINTRAC, which reports to the Minister of Finance, facilitates the detection, prevention, and deterrence of money laundering and the financing of terrorist activities, while ensuring the protection of personal information under its control.

FINTRAC is one of 13 federal departments and agencies that play a key role in Canada’s AML/ATL regime, which is led by the Department of Finance Canada. As Canada’s Financial Intelligence Unit and AML/ATF Supervisor, the Centre helps to combat money laundering, terrorist activity financing and threats to the security of Canada.

The Centre is able to fulfill its financial intelligence mandate, by working with Canadian businesses through its supervisory function to ensure compliance with the PCMLTFA and associated regulations. Compliance with this Act helps to prevent, detect and deter criminals from using Canada’s economy to launder the proceeds of their crimes or to finance terrorist activities. It also ensures the Centre receives the information that it needs to produce actionable financial intelligence for Canada’s law enforcement, national security agencies, other domestic agencies and foreign financial intelligence units in relation to these threats.

FINTRAC also generates valuable strategic financial intelligence, including specialized research reports and trends analysis, for regime partners and policy decision-makers, businesses, and international counterparts. This strategic financial intelligence shines a light on the nature, scope, and threat posed by money laundering and terrorist financing.

Supervision—In accordance with the first of its two operational mandates, FINTRAC is responsible for ensuring that all persons and entities subject to the PCMLTFA and associated regulations (reporting entities) comply with their legal obligations, including those related to client identification, record keeping, and reporting. These include an obligation for all reporting entities to determine in specific circumstances whether an individual is a domestic politically exposed person (PEP), a foreign PEP, a head of an international organization (HIO), or a family member or close associate of one of those individuals.Footnote xxviii Once the reporting entity has made this determination, it must assess whether a domestic PEP, an HIO, or their family member or close associate poses a high risk for committing a money laundering offence or a terrorist financing offence and, if required, must undertake other specific measures. Foreign PEPs, their family members and their close associates must automatically be treated as high-risk clients. FINTRAC supervises and enforces reporting entities’ compliance with domestic and foreign PEP obligations. This includes assessing that controls are effective and that suspicious transactions are reported to FINTRAC when a transaction or deposit is related to the commission or the attempted commission of a money laundering or a terrorist financing offence. In instances of unreported suspicious transactions related to a domestic or foreign PEP, FINTRAC may impose administrative monetary penalties or disclose non-compliance to law enforcement.

FINTRAC provides comprehensive guidance on domestic and foreign PEP obligations and risk-mitigating measures for high-risk clients to build awareness and to ensure consistent internal and external communication of regulatory compliance requirements.

Actionable Intelligence—In accordance with its second operational mandate, FINTRAC, based on its analysis and assessment, produces actionable financial intelligence that it must disclose to the police and other domestic recipients listed in the PCMLTFA when specific legal thresholds are met. Prior to disclosing tactical financial intelligence, FINTRAC must have reasonable grounds to suspect that the information it is authorized to disclose would be relevant to investigating or prosecuting a money laundering offence, a terrorist financing offence, a sanctions evasion offence, or would be relevant to threats to the security of Canada. In addition to disclosing financial intelligence to domestic recipients, FINTRAC also maintains over 100 memorandums of understanding with foreign financial intelligence units, to which it is authorized to disclose financial intelligence relevant to money laundering, terrorist financing, sanctions evasion, or a substantially similar offence. Between September 1, 2024, and May 15, 2025, FINTRAC produced 39 disclosures relevant to money laundering, which also included information related to bribery and/or corruption. Of these, 13 were disseminated to a foreign recipient. Furthermore, as part of FINTRAC’s commitment to being a centre of excellence on money laundering and terrorist financing matters, intelligence analysts and compliance officers from the Centre regularly attend training sessions involving corruption.

Raising Awareness—FINTRAC uses various means to enhance public awareness and understanding of ML and TF. These include operational alerts, briefs, and assessments and public-private partnerships. FINTRAC also produces strategic financial intelligence, including specialized research reports and trends analysis on ML, TF, sanctions evasion and the financing of threats to the security of Canada, which can be used by police, the Canadian security and intelligence community, federal policy and decision-makers, reporting entities across the country, and other stakeholders. In May 2023, FINTRAC published a special bulletin on the money laundering techniques that may be deployed by Russia-based individuals and entities sanctioned by the Government of Canada—particularly those whose financial assets have been acquired through corruption and other illegal activities—to evade sanctions and move financial assets outside of Russia.

Global Affairs Canada (GAC)

Global Affairs Canada (GAC) plays a lead role in representing Canada at international anti-corruption forums, such as the OECD WGB and the United Nations Convention Against Corruption (UNCAC)’s Implementation Review Group, in outreach efforts with emerging economies regarding corruption, as well as coordinating Canada’s whole-of-government approach to meeting its international anti-corruption obligations.

Trade Promotion—Canadian embassies and offices abroad (also known as missions) raise awareness of Canada’s CFPOA among Canadian companies active overseas. They are also provided instructions on the steps that should be taken when a Canadian company or individual is alleged to have bribed a foreign public official or committed other bribery-related offences. Canada’s missions are charged with conveying relevant information to Canadian law enforcement in accordance with Canadian law and established procedures.

Canada’s responsible business conduct (RBC) strategy, Responsible Business Conduct Abroad: Canada’s Strategy for the Future, provides a framework for Canada’s RBC approach to, which includes preventative measures, legislation in select areas and access to remedy in the form of non-judicial dispute resolution mechanisms. It applies to all Canadian companies, no matter their size, sector, or scope, and encompasses anti-corruption and anti-bribery efforts as part of its broader RBC efforts.

Trade, Development, Risk Management, and Reporting Obligations—GAC continues to apply the 2010 Policy and Procedure for Reporting Allegations of Bribery abroad by Canadians or Canadian Companies, which instructs Canadian missions on the steps that must be taken when allegations arise that a Canadian company or individual has bribed a foreign public official or committed other bribery-related offences. Information is conveyed to law enforcement in accordance with Canadian law and established procedures. In addition, since September 2014, Canadian companies are asked to sign Integrity Declarations (previously known as Declarations Regarding Corruption) before any trade advocacy support services are provided by Canadian missions abroad. Signed Integrity Declarations are valid for one, two or three years, and must be resubmitted after they expire before new trade advocacy support services can be provided. Since 2014, 6,063 Integrity Declarations have been signed by Canadian companies, and as of July 2025, 1,065 Declarations are currently in force.

Canada’s International Assistance—International assistance programs undertaken by GAC aim to work with developing country partners to lower the risk of corruption by improving accountability and transparency in the delivery of public services. Reducing opportunities for corruption and increasing constraints on corrupt actors by supporting women’s participation in governance and decision-making processes improves integrity in the delivery of services that matter to people in their communities. This is critical for understanding and addressing the root causes of corruption in a way that takes into account women’s unique perspectives and experiences.

Furthermore, Canada’s broader international assistance programming in support of governance and civil society engagement strengthens anti-corruption capacity within government and civil society, although anti-corruption results to which these programs contribute are not currently tracked by GAC.

This programming may include efforts to:

GAC continues to improve its tools for managing fiduciary risks in international assistance. As part of GAC’s Grants and Contributions Transformation Initiative, work is underway to integrate risk-management processes for all of GAC’s grants and contributions. The Risk Management Advisory Group is a key platform for engaging a broad range of programs in risk management. The framework to promote a consistent and systematic approach to managing risk has been developed with a focus on facilitating knowledge sharing and reducing duplication. The harmonized and adaptable risk management component is expected to be integrated into departmental systems by December 2025 and gradually rolled out to all grants and contributions programs thereafter.

GAC has a dedicated Grants and Contributions Fraud Management Unit (Unit) to support fraud prevention, detection, and management within its grants and contributions portfolio. The Unit provides advisory services on fraud management and manages reporting channels on allegations of financial misconduct related to grants and contributions. The Unit relies on internal and external investigation capacity to conduct investigations when deemed appropriate and is also responsible for raising awareness and building capacity within recipients and internal stakeholders on fraud prevention and detection, and tools to achieve this goal are still in progress. Since the beginning of this year, the Unit has been utilizing an enhanced database to efficiently track and follow up on fraud cases, make data-driven decisions, and create dashboards for improved decision-making. The Grants and Contributions Fraud Review Committee provides governance and oversight over fraud risk management activities, including support to the Chief Financial Officer and Director General of the Grants and Contributions Centre of Expertise with recommendations on courses of action for cases requiring the Committee’s attention due to their complexity, potential impact or other considerations. The Committee’s composition includes General Counsel representation. The Unit is continuing its outreach to other donors, building on previous efforts to explore collaboration opportunities in the fight against fraud.

Through the audit and compliance team, GAC also supports its new partners and conducts financial capacity-building activities, which include reviewing the organizations’ internal controls to deter and report fraud. This activity also serves to remind organizations of their obligations related to reporting substantiated or suspected fraudulent activities, as well as other requirements outlined in the GAC terms and conditions for development projects.

In addition, GAC is funding the Transparency International project, “Inclusive Service Delivery Africa” ($9.7 million, 2021-2025), which aims to close the gender-related corruption loopholes and vulnerabilities in health and education service delivery in five countries in sub-Saharan Africa: Republic of Congo, Ghana, Madagascar, Rwanda, and Zimbabwe. Based on lessons learned from previous anti-corruption programming, the project establishes and operates Advocacy and Legal Advice Centres and collaborates with women’s rights and civil society organizations, and journalists at local and national levels to promote women’s rights and participation in demanding their rights to receive accountability in public service delivery.

GAC is also funding the Transparency International project “Clean Money in Elections” ($2.2 million, 2023-2026), which aims to enhance accountability of political parties and candidates for transparency and gender equality of political finance to voters in Indonesia, Madagascar, Panama, Sri Lanka, Venezuela, and Zambia. Improved transparency in election and political party financing supports competitive democratic processes and equal opportunities for female candidates.

Since 2015, Canada has been actively engaged in the global Methodology for Assessment of Procurement Systems (MAPS) initiative, centred on a universal tool used to evaluate the quality of public procurement systems, including specific anti-corruption measures.Footnote xxix The core tool features enhanced accountability, integrity, and transparency assessment criteria. Since 2018, assessments of dozens of countries have been undertaken. For the development portfolio, MAPS assessments are used as part of fiduciary risk due diligence when considering programming approaches that rely on country systems. Links to MAPS and other key complementary resources on anti-corruption in public procurement are integrated into GAC’s corporate guidance. Canada supported the establishment of an independent secretariat in 2020, hosted by the OECD, to maintain MAPS, ensure quality control, and certify and publish assessments when requested by countries.

Training and Outreach—Every year, GAC personnel responsible for trade matters and support to Canadian companies doing business abroad are invited to participate in an RBC training that includes information on anti-corruption policies and procedures. This year’s edition was delivered in May 2025 to 44 participants, in partnership with CCC and the RCMP. The training typically includes modules on Canada’s international obligations to prevent and combat corruption, officials’ responsibilities pursuant to the CFPOA and reporting procedures, and corruption concerns in specific markets.

In addition, missions abroad and regional offices in Canada can apply for funding through GAC’s internal Responsible Business Fund to deliver RBC initiatives in their respective regions. Initiatives can include anti-corruption content and participation in various activities organized by local and bilateral chambers of commerce, government organizations (local, national, international), and multilateral organizations.

Participation in these activities can reinforce key messaging on RBC and anti-corruption, with emphasis on the CFPOA, and how it affects Canadian companies doing business abroad. For this reporting period, GAC worked with the RCMP and other partners to deliver three anti-corruption focused initiatives for different markets, as well as a joint training session for Canada’s Trade Commissioners (TCs) attending the Prospectors and Developers Association of Canada (PDAC) convention in Toronto in March 2025.

In 2019, GAC joined the U4 Anti-Corruption Resource Centre (U4),Footnote xxx whose mission is to help reduce the harmful impact of corruption on sustainable and inclusive development. The benefits to all staff—at headquarters and in missions—include access to opportunities for online training and for specialized in-country workshops in sectors vulnerable to corruption, the helpdesk, and an extensive collection of research publications and tools. Since 2020, GAC has extended access to online training to its recipient organizations. Funding to Ukraine from the international community, including Canada, supported anti-corruption efforts being embedded in Ukraine’s stabilization and reconstruction. Since 2023, a dedicated workstream, including Ukrainian-language online training, as well as the development of briefs/reports, as well as tailored advice and guidance informs practical anti-corruption efforts on the ground. U4 continued to pursue evolving themes, such as corruption risks related to climate change finance, extractive industries, fragile states, peace and security, and collaborative approaches.

Innovation, Science and Economic Development Canada (ISED)

Beneficial ownership reporting obligations in Canada—Corporate law is an area of shared jurisdiction in Canada among the federal, provincial, and territorial levels. In Canada, a corporation can choose to incorporate federally with Corporations Canada or provincially with a province or territory. There are several federal and provincial laws and regulations in Canada that include provisions on beneficial ownership of legal entities or arrangements, including, but not limited to:

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)—The PCMLTFA and its regulations, the Proceeds of Crime (Money Laundering) and Terrorism Financing Regulations (PCMLTFR), specify measures that regulated reporting entities (businesses and professions) should take to protect themselves against misuse for money laundering and terrorism financing. The PCMLTFR provides the following definition of beneficial owners of legal persons and legal arrangements:

Moreover, under subsection 138(1) of the PCMLTFR, reporting entities, which are businesses and professions regulated for AML purposes, are required to verify the existence of an entity that is a corporation, as well as obtain and verify information on that company’s beneficial owners when they establish business relationships with such entities or conduct certain transactions.

Reporting entities under the PCMLTFA that provide financial services to corporations, trusts and partnerships are required to conduct due diligence to ensure they know their customer and beneficial owners and report transactions, as required.Footnote xxxi As part of this due diligence, reporting entities will be required, starting in October 2025, to flag any discrepancies between the information on the federal beneficial ownership registry (discussed further below) and the information they receive as part of their “know your client” obligations.

Canada Business Corporations Act (CBCA) and comparable provincial/territorial incorporation statutes—In Canada, the federal CBCA requires private corporations to maintain and update a register of “individuals with significant control” (ISCs or beneficial owners) of the corporation. The Act defines “individual with significant control” of a corporation as “an individual who:

  1. has any of the following interests or rights, or any combination of them, in respect of shares of the corporation carrying either 25% or more of voting rights, or 25% of its shares measured by fair market value—
    1. the individual is the registered holder of them,
    2. the individual is the beneficial owner of them (which includes ownership through any trustee, legal representative, agent or mandatary, or other intermediary), or
    3. the individual has direct or indirect control or direction over them;
  2. has any direct or indirect influence that, if exercised, would result in control in fact of the corporation; or
  3. has circumstances as prescribed by regulation apply to them.”

Two or more individuals are also each considered to be an ISC if they jointly hold shares that surpass one of the thresholds for a single ISC, or act in concert under an agreement or arrangement with respect to shares that surpass one of them.

At least once during each financial year of the corporation, it must take reasonable steps to ensure that it has identified all ISCs and that the information in the register is accurate, complete and up to date. Additionally, if the corporation becomes aware of any new ISC information, it is to record that information in the ISC register within 15 days. When canvassing registered shareholders for ISC information, the shareholders have a statutory duty to reply accurately and completely, to the best of their knowledge, as soon as feasible.

In 2019, further amendments were made to the CBCA to allow investigative bodies to make a request to these corporations to provide information from their registers where authorities believe it would be relevant to an investigation. Regulations have been made to instruct corporations on the following: the manner of preparing and maintaining the ISC register; the reasonable steps they must take to collect the information; and what to do where no ISCs can be identified.

Most provinces and territories (representing 88% of all corporations) have since amended their legislation requiring private corporations to create and maintain a register of beneficial ownership information and to disclose that information, upon request, to relevant authorities.

Public Beneficial Ownership Registry—In 2022, federal legislation was passed that require most federally incorporated companies to proactively submit information on their beneficial owners to Corporations Canada, on an annual basis, or when a change in control occurs. The amendments will also allow Corporations Canada to disclose all, or part of that information received from corporations to investigative bodies, FINTRAC and other prescribed entities.

In 2023, further federal legislation was passed that permits Corporations Canada to:

  1. Make public certain information regarding the beneficial owners received from federal corporations while introducing an exemption regime for certain individuals;
  2. Protect whistleblowers;
  3. Bolster the powers of Corporations Canada to make enquiries and create new penalties to ensure robust compliance with the new regime; and,
  4. Amend other federal statutes, namely the PCMLTFA, the Income Tax Act and the Access to Information Act (ATIA).

The PCMLTFA was amended to allow the enactment of regulations that will require reporting entities that are subject to the PCMLTFA and its regulations, upon becoming aware of any material discrepancies between the beneficial ownership information they obtain from a corporation and the information that a company may have filed to the registry, to alert the registry for follow-up. Meanwhile the Income Tax Act was amended to allow the CRA to share certain information with Corporations Canada that would support the validation and verification of the beneficial ownership information filed by federal corporations. This cross-referencing of beneficial ownership data would supplement Corporation Canada’s compliance efforts by alerting it to potential errors and inconsistencies, improving data integrity and its value for end users, such as law enforcement, tax authorities, and reporting entities themselves.

On January 22, 2024, corporations incorporated under the CBCA began sending their information on their ISCs to Corporations Canada. Some of the ISC information is then made available to the public, namely:

Information that is not public (only available to law enforcement and authorized entities)

Under the CBCA, a corporation is required to take reasonable steps, at least once during each financial year of the corporation, to ensure that it has identified all beneficial owners and that the information in the register is accurate, complete, and up to date. Additionally, if the corporation becomes aware of any new ISC information, it is to record that information in its ISC register within 15 days and to file the new information with Corporations Canada. When canvassing registered shareholders for beneficial ownership information, the shareholders have a statutory duty to reply accurately and completely, to the best of their knowledge, as soon as feasible. Several provinces have adopted similar rules. As noted above, Corporations Canada can disclose all or part of that information received from corporations to investigative bodies including the RCMP, the CRA, FINTRAC, and other bodies as prescribed in regulations.

In 2023, Québec launched its public beneficial ownership registry, overseen by the Registraire des entreprises du Québec. The registry covers businesses carrying on commercial activities in that province, including corporations, partnerships, fiduciaries, or trusts operating a commercial enterprise, sole proprietorships and certain cooperatives. In 2023, British Columbia passed legislation to create a public beneficial ownership registry, which is expected to be launched in 2025. In the 2024 Ontario Economic Outlook and Fiscal Review, Ontario announced that it is also exploring options for a beneficial ownership registry. In the 2025 Ontario Budget: A Plan to Protect Ontario, Ontario announced its intention to explore registry options and to launch public consultations to “inform the establishment of a beneficial ownership registry, and other potential measures to empower regulators and law enforcement to fight money laundering and the financing of organized crime.”

Provincial/territorial securities legislation–beneficial ownership reporting—There are three general requirements for beneficial ownership transparency in securities law:

Additional background on each of these requirements is set out below.

Early Warning Requirements (National Instrument 62-103 and Part 5 of National Instrument 62-104)

Insider Reporting Requirements (National Instrument 55-104)

Management Information Circular Disclosure Requirements (Form 51-102F5 Item 6.5 of Part 2)

Income Tax Act—All trusts, unless specific conditions are met, must file a trust return and Schedule 15 for tax years ending after December 30, 2023. Trusts must report the identity of all trustees, beneficiaries and settlors of the trust, along with each person who has the ability (through the trust terms or a related agreement) to exert control or override trustee decisions over the appointment of income or capital of the trust (for example a protector). For bare trusts, the CRA has waived the requirement for the 2023 tax year and is working to clarify the reporting requirements for 2024 and beyond. 

In addition, details about the legal ownership of medium and large corporations operating in Canada have to be filled annually with Statistics Canada pursuant to the Corporations Returns Act and are available to both the public and law enforcement.

Natural Resources Canada (NRCan)

The Extractive Sector Transparency Measures Act (ESTMA) requires mining, oil, and gas companies active in Canada to disclose publicly, on an annual basis, certain types of payments made to governments in Canada and abroad. These disclosures raise transparency, reduce corruption, and enable communities to hold their governments to account for the revenues generated from oil, gas, and mining resources. Relevant activities during this reporting period have included the below.

Ongoing implementation of the ESTMA Compliance Program—Natural Resources Canada (NRCan) conducted compliance reviews and activities in line with the ESTMA Compliance Program during this period, which supports data integrity and effective administration of the Act. The compliance program relies on data analytics based on reputable data sources to identify companies at the highest risk of non-compliance. This includes gathering data from ESTMA reports and leveraging data from public Canadian securities filings, reputable paid corporate databases, and international corruption indexes. Further, the process includes reviewing media reports for companies that have been flagged as high-risk for non-compliance, as well as regular flagging of media reports to the team that implements the ESTMA. Once entities that have been deemed to be at risk of non-compliance with ESTMA requirements are identified through research and data analytics, NRCan issues requests for information to substantiate any compliance issues and orders corrective measures to address them. Individuals can also submit third-party complaints to NRCan about extractive entities or ESTMA reports, including potential missing payments. Lastly, NRCan is implementing a new ESTMA reporting portal that will modernize the report submission process, and which is expected to improve data integrity and compliance monitoring.

Ongoing stakeholder engagement and compliance promotion—NRCan continues to undertake compliance promotion activities to ensure that stakeholders are aware of the ESTMA reporting requirements. This includes regular mailers to ESTMA Reporting Entities highlighting findings from compliance reviews and any recent program developments. NRCan also encourages Government of Canada departments and external stakeholders to use ESTMA data for relevant activities whenever possible.

Updated Data Portal—The ESTMA Data Portal continues to be updated regularly. The data portal allows users to search the payment information by entity, payee and project, and includes summaries of key data points and visualizations.Footnote xxxii NRCan collects feedback from stakeholders to support regular updates, including through meetings and events.

Website regularly updated with the latest information—NRCan conducts periodic reviews to update website sections about ESTMAFootnote xxxiii to reflect the latest information. During this period, key website updates have included the release of a revised ESTMA Report Validation Checklist and updated substitution determinations for reports from international jurisdictions that have implemented transparency reporting requirements similar to the ESTMA.

Public Prosecution Service of Canada (PPSC)

Prosecutions—The PPSC prosecutes criminal offences under federal statutes, including the CFPOA, on behalf of the AGC. To ensure a standard approach to the prosecution of offences under the CFPOA, the PPSC has established a subject-matter expert position located in Ottawa for international corruption cases. The subject-matter expert has developed linkages with the RCMP Federal Policing Criminal Operations (FPCO) directorate and other key government interlocutors involved with the enforcement and development of the CFPOA.

Training and Outreach—Internally, training in relation to the CFPOA has been provided to designated contacts in each of the PPSC’s regional offices. These contacts, who are generally senior prosecutors, will act as local points of contact and coordinators in relation to CFPOA matters as they arise for prosecution. In addition, presentations have been made to the PPSC’s regional directors to increase awareness of the OECD Convention, the CFPOA, and the current activities of the RCMP and the PPSC in this area. The PPSC has also made presentations and actively participated in panels raising awareness of Canada’s anti-corruption activities.

Public Services and Procurement Canada (PSPC)

Combating Corruption—To help ensure the Government of Canada does business with ethical suppliers, PSPC’s Office of Supplier Integrity and Compliance (OSIC) administers Canada’s government-wide debarment and suspension program, which is designed to reduce the risk of the Government of Canada doing business with unethical suppliers, hold suppliers accountable for their misconduct, and encourage more ethical business practices.Footnote xxxiv

The Ineligibility and Suspension Policy (Policy) sets out when and how a supplier may be declared ineligible or suspended from doing business with the Government of Canada.

Under the Policy, Canada may suspend or debar a supplier from being awarded a contract or real property agreement on the basis of charges, convictions, and additional circumstances listed in the Policy. This includes charges and convictions related to corruption, fraud, bribery and foreign bribery, terrorist financing, the use of human trafficking/forced labour in Canada or a similar offence abroad, and similar offences recognized in provincial and foreign civil judgments. OSIC can also take action in the absence of charges or convictions, including in cases in cases where: the supplier has been debarred by another jurisdiction or an international organization; it is determined that contracting with a supplier may bring the federal government into disrepute or is contrary to Canadian public policy; or where it is determined that a supplier lacks business honesty or business integrity in a manner that seriously and directly affects their present responsibility. A supplier may be debarred for a period of up to ten years based on an assessment of aggravating and mitigating factors.

The names of ineligible and suspended suppliers, as well as those who have entered into an Administrative Agreement with PSPC, are published on PSPC’s website at the following links:

The Policy is incorporated into solicitations, resulting contracts, and real property agreements that incorporate the Policy by reference.

Currently 89 federal institutions (86 departments and agencies and three Crown corporations) have signed memorandums of understanding with PSPC to apply the Policy and obtain supplier integrity verification services. This allows organizations to verify that a supplier is not ineligible to conduct business with the Government of Canada under the Policy prior to awarding a contract or real property agreement.

OSIC is also responsible for the development and deployment of additional data analytics capacity, which is a key tool for detecting fraudulent schemes and other types of wrongdoing and better leveraging intelligence relevant to assessing the integrity of suppliers.

Raising Awareness—PSPC works closely with the private sector, industry partners, and civil society organizations to promote an ethical business culture and integrity in public procurement. Senior PSPC officials participate as guest speakers and deliver presentations at a range of events on Canada’s approach to combating fraud and corruption in procurement and real property processes, the work of OSIC and implementation of the Policy, and PSPC’s Fraud Risk Management Framework. Since the launch of OSIC, PSPC has actively worked to heighten awareness of its activities. For example, PSPC provides updates to Canada’s debarment and suspension program with communiques, training sessions for procurement and real property officers across the Government of Canada, and engagement with the supplier community. PSPC also engages senior officials across the federal government to ensure consistent application of the Policy, and to increase awareness and promote the referral of cases misconduct to OSIC for assessment.

PSPC collaborates with federal partners on measures to prevent, mitigate, and address unethical business practices within public procurement and real property processes. This includes participating in working groups, committees and bilateral meetings. PSPC is also actively involved in discussions with like-minded countries to share lessons learned on emerging trends related to corruption and federal procurement.

PSPC has made it a priority to deliver awareness initiatives as a means to inform suppliers and employees, as well as the general public, about the types of activities that could constitute fraud, such as bribery, and the channels to report it, including the internal disclosure process and the Tip Line. For example, PSPC engages in regular fraud awareness campaigns, using a variety of communications tools, such as social media accounts, employee newsletters, the Canadian vendor mobile app, and supplier procurement portals.

The heightened awareness about fraud from these campaigns has resulted in new collaborations between PSPC and other government departments where knowledge and experience regarding fraud detection and investigation methods are shared.

Royal Canadian Mounted Police (RCMP)

Enforcement—The International Anti-Corruption Program is governed under the umbrella of the RCMP FPCO directorate. The FPCO provides subject matter expertise internally and externally to national and international partners, including government departments. The RCMP has the capability to track all CFPOA cases. Since 2014, aided by its exclusive authority to lay an information in respect of CFPOA offences, the RCMP expects that all credible foreign bribery allegations, including those initially reported to Canadian law enforcement agencies or other government officials, such as those in foreign missions, will be referred to the RCMP for evaluation and investigation if deemed appropriate.

To date, the RCMP has received information from various reliable sources, including former employees of corporations involved in alleged corruption, GAC, Canadian law enforcement agencies, foreign law enforcement agencies via MLA requests, International Criminal Police Organization – INTERPOL, non-governmental organizations, and corporations and/or their law firms representing these corporations who are self-reporting.

Among other responsibilities, the RCMP is responsible for investigating offences under the CFPOA. It is tasked with:

Allegations of corruption can have serious repercussions in relation to business transactions and international relations. They are taken very seriously by the RCMP and treated with the utmost confidence for reasons of privacy and ensuring the integrity of JUS investigations.

The RCMP has an established point of contact within JUS’ IAG to ensure that priority is given to requests for MLA in foreign bribery matters.

RA Regime—The enactment of the legislation in 2018 and its application by the courts in 2023 in a case of international corruption committed by a Canadian company (Ultra Electronics Forensic Technology Inc.) has led to an increase in corporate self-reporting and cooperation with law enforcement.

Training and Outreach—The RCMP remains committed to its crime prevention initiatives, efforts to promote awareness, education, and capacity building both domestically and internationally, which it views as a critical component of its anti-corruption efforts. To that end, the RCMP ensures that all corruption-related material on its internal and external websites is kept up to date on an ongoing basis. Furthermore, during September 2024, the RCMP hosted a 4-day training workshop for RCMP officers, criminal intelligence analysts, and PPSC prosecutors in relation to investigating CFPOA offences.

The RCMP has been proactive in reaching out to key stakeholders and developing partnerships with various organizations and institutions to promote its prevention efforts and initiatives. The RCMP continuously seeks to leverage opportunities, such as International Anti-Corruption Day, media requests, conferences and selected anti-corruption workshops to promote its efforts to prevent corruption-related offences. In addition, the RCMP commits resources on a full-time basis to work with the International Anti-Corruption Coordination Center in London, England, in order to provide bribery and corruption awareness training, mentorship to anti-corruption investigators, and build partnerships, while also identifying allegations of corruption with a nexus to Canada. In May 2025, the RCMP provided an English and a French session virtually to GAC. These sessions targeted the next rotation of TCs heading overseas. Both sessions were designed to provide current information on CFPOA enforcement and provide TCs with the knowledge and comfort to initiate difficult conversations with Canadian companies operating overseas in high-risk areas. In addition, from September 2024 to August 2025, the RCMP participated in multiple conferences as subject matter experts on anti-corruption prevention, RAs and effective cooperation with law enforcement. These local and international conferences were conducted in partnership with key stakeholders, including participating in the International Anti-Corruption Conference in Lithuania for capacity building, developing partnerships, and sharing best practices. The RCMP’s participation in these international conferences confirms an international recognition of its expertise in combating international corruption.

The RCMP continued its outreach work and maintained its engagement with contacts using videoconference, social media websites and the RCMP website to raise awareness on the CFPOA and the role of the RCMP in the RA regime. As an example, on March 14, 2025, the RCMP, in partnership with GAC and the Canadian Chamber of Commerce in Mexico, participated in a virtual webinar on corruption for Canadian companies operating in Mexico. In addition, the RCMP has regularly responded to domestic and international partners for capacity building to combat corruption and has also provided presentations to various university programs in Canada.

The RCMP continues to collaborate with local and foreign partners by sharing expertise and best practices. For example, in furtherance of developing stronger prevention practices, in October 2024 and May 2025, the RCMP hosted international delegations where the RCMP continued fostering the exchange of knowledge and strengthening international collaboration in the ongoing fight against corruption.

The RCMP continued its visibility and worked in partnership with or proactively sought referrals from various departments, agencies and organizations. The RCMP has worked with, inter alia, GAC, the Canadian Ombudsperson for Responsible Enterprise, ISED, PSPC, PPSC, and the CCC.

This year, the annual Prospectors and Developers Association of Canada (PDAC) mining convention was held in March 2025. The RCMP was in attendance and worked in collaboration with TCs to prepare for the event.

International Foreign Bribery Taskforce—The RCMP and its Five Eyes partners (the United Kingdom, United States, New Zealand and Australia), meet annually as the International Foreign Bribery Task Force (IFBT) to discuss foreign corruption investigations, share best practices and challenges, and collaborate/leverage police-to-police exchange of information. In October 2024, the RCMP attended the annual IFBT meetings in England.

Treasury Board Secretariat (TBS)

The Treasury Board Secretariat (TBS) provides advice and makes recommendations to the Treasury Board committee of ministers on how the federal government spends money on programs and services, how it regulates, and how its human resources are managed. To achieve these objectives, the TBS sets the government-wide management agenda and provides guidance to departments on a wide range of management issues.

Public confidence is enhanced, and a culture of accountability and integrity is promoted, when there are effective mechanisms to combat and address the bribery of foreign public officials. This includes having effective procedures for disclosing wrongdoing and for protecting those who disclose wrongdoing and acts of corruption within the public sector.

The external task force conducting a statutory review of Canada’s Public Servants Disclosure Protection Act (PSDPA), has completed its extensive consultations with internal and external stakeholders, ensuring that diverse perspectives and expertise were considered. It has also completed its review of best practices related to whistleblower regimes within Canada and internationally. In preparing its report on recommendations to the Government of Canada, the task force is considering how the PSDPA can effectively protect and empower public servants to shine a light on wrongdoing, protect them when they do, and help strengthen Canadians’ confidence in the integrity of its public institutions.

During the reporting period, Canada continued to strengthen the guidance and implementation of the internal disclosure process. This included updates to the mandatory foundational values and ethics training for public servants and managers, placing greater emphasis on the prevention and management of wrongdoing. Additionally, standardized briefings are being developed to support Senior Officers for Internal Disclosure in fulfilling their key role in promoting, supporting, and facilitating the internal disclosure process.

On the international front, Canada continues to be represented by a TBS official as a member of the OECD Working Party on Public Integrity and Anti-Corruption (PIAC), a sub-group of the OECD’s Public Governance Committee. The PIAC aims to strengthen public sector governance and institutions involved in policymaking related to safeguarding integrity and preventing corruption, including strengthening the underlying conditions that shape policymaking processes. As a member of the PIAC, Canada regularly provides technical guidance to other OECD member countries on the promotion of integrity frameworks related to public governance. During the reporting period, Canada’s representative contributed to discussions on integrity and anti-corruption at the OECD’s 2025 Global Anti-Corruption and Integrity Forum held in Paris.Footnote xxxvi

In May 2024, the Government of Canada’s Trust and Transparency Strategy (Strategy) was released. The Strategy aims to strengthen public trust in federal institutions through a comprehensive, whole-of-government approach. This Strategy is grounded in three core principles: transparency, accountability, and participation. It focuses on enhancing openness, improving access to information, and fostering meaningful public engagement in decision-making processes.

In September 2022, the President of the Treasury Board released Canada’s 2022–24 National Action Plan on Open Government. National Action Plans (NAPs) are released every two to four years as part of Canada’s membership in the Open Government Partnership. They serve as a mechanism for the Government of Canada to improve transparency, public participation, and accountability in government processes and operations. During each NAP planning cycle, Canadians can engage in how government makes decisions and directly shape activities within the Plan. The 2022-24 NAP worked toward advancing openness, transparency, and accountability in the Government of Canada through goals set in five thematic areas: climate change and sustainable growth; democracy and civic space; fiscal, financial, and corporate transparency; justice; and open data for results. The implementation cycle for the 2022-24 NAP ended on December 31, 2024. Canada is now in the process of co-creating its 2025-29 NAP with input from Canadians. Also, by continuing to improve the Access to Information and Privacy Online Request Service (ATIP Online),Footnote xxxvii the Government of Canada is making it easier for Canadians to access government information.

Further to Action Plan Commitments, in 2022, the Evaluation of Proactive Publication Under the ATIAFootnote xxxviii was completed, recommending that the TBS foster institutional monitoring to better understand the compliance of institutions with their proactive publication obligations, and to promote and support the use of ATIP Online. Compliance challenges have arisen due to inconsistencies in institutional practices and the complexity of reporting requirements across different government entities. Some institutions have faced difficulties in standardizing their publication processes, leading to delays or gaps in proactive disclosure. In response, the TBS has published a Directive on Proactive Publication under the ATIA,Footnote xxxix communicating directions to institutions on institutional monitoring and to make ATIP Online the prescribed platform for publishing records under ATIA Part 2–Proactive Publication of Information. These initiatives are intended to promote transparency and openness by ensuring that proactive publication records are consistently available from a central source.

The Guide to the Proactive Publication of Contracts (the Guide)Footnote xl provides guidance to managers and functional specialists on the identification, collection, reporting and publication of contract information. The Guide was amended in 2023 to include additional requirements to strengthen guidance on monitoring of the proactive publication of contract information and reporting on contract descriptions for certain services contracts.

Among other purposes, contracting data is gathered to strengthen the transparency of the procurement process for Canadians to hold their government to account. The Guide supports the proactive publication of contract information by government entities and Ministers’ offices under Part 2 of the ATIA, which requires the proactive publication of: contracts with a value of over $10,000; a contract amendment when it modifies the contract value to exceed $10,000; and amendments to contracts that increase or decrease the value of the contract by more than $10,000. Appendix A of the Guide presents the data elements for annual reporting to PSPC and the quarterly proactive publication on the Open Government Portal. Appendix B of the Guide presents the data elements for the annual reporting and publication of the aggregate contract and amendment activity for contracts $10,000 and under on the Open Government Portal.

The Guidelines on the Reporting of Grants and Contributions AwardsFootnote xli provide guidance to managers and functional specialists on the identification, collection, and publication of grants and contributions (Gs&Cs) award information. These Guidelines support the public disclosure requirements of Gs&Cs award information for government entities under the ATIA, which requires government entities to proactively publish: Gs&Cs awards exceeding $25,000; Gs&Cs awards that are of a value of $25,000 or less that were amended to exceed the $25,000 threshold; and any amendments to these Gs&Cs awards. Additionally, in line with the Government’s commitment to transparency and Open Government, agreements under $25,000 must also be published.

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