Canadian sanctions guidance — Academic and research sector

This guide is designed to help academic and research institutions understand sanctions compliance and manage sanctions risks. This information is not exhaustive. It is recommended that each institution have a sanctions compliance program in place and review new measures on an ongoing basis. Consult with private legal counsel, as required. For information on Canada’s sanctions regime see Canadian sanctions. Additional resources can be found under thematic guidance.

Overview

When sanctions are implemented in Canada, Canadians abroad, and those in Canada, can face limitations in dealing or collaborating with sanctioned countries, or listed individuals, and entities.

Academic and research institutions in Canada need to be aware of Canadian sanctions and how they may impact their work and relationships. Sanctions do not prohibit providing employment, education or training services to all individuals from sanctioned countries. However, enrolling a student or hiring or hosting academic staff from a sanctioned country will need to be considered in the context of Canada’s sanctions regime. For example, a foreign student or faculty member engaged in an area related to the export of listed goods, sanctioned activities or services, or those with links to a listed individual or entity, increases the risk of a potential sanctions violation.

Academic and research institutions also need to be mindful of attempts to circumvent Canadian sanctions under the guise of international academic collaboration, or through foreign students, visiting professors and foreign workers. Through privileged access to university or college networks, research and infrastructure, such actors may collect information, monitor digital traffic, or facilitate data theft. The transfer of knowledge, particularly when used for military application and surveillance purposes, poses major challenges and risks to Canada and its allies.

Due diligence

Canada encourages the effective and robust enforcement of sanctions through rigorous due diligence, which can help assess whether an activity may trigger sanctions.

Canadian sanctions change frequently. Subscribe to receive sanctions updates and monitor the latest announcements on Canada’s sanctions, including new additions to the sanctions lists and sanctions regulations.

Any suspected sanctions evasion should be reported to the RCMP.

There are some key considerations when engaging with international academic institutions, foreign students, professors, or other individuals. These are for:

Involvement of listed individuals or entities

Screen any proposed engagement against the UN consolidated list and the Canadian autonomous sanctions list to determine if the individual or entity you propose to engage with is directly subject to Canadian sanctions. This includes, for example, hiring faculty, admitting foreign students, or those involved in research collaborations.

While it is generally prohibited to deal directly with listed individuals and entities, indirect dealings are an important consideration. Under most Regulations made pursuant to the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act, it is prohibited to enter into or facilitate a transaction related to a dealing with a listed person or entity – even indirectly, such as through a third party – including if that third party is not Canadian and/or is located outside of Canada. See Dealings prohibition and asset freeze for more information.

Questions to consider:

Am I dealing with a person that deals with a listed individual or entity?
- Does the prospective student, staff member or research collaboration have any connection, even indirectly, with a listed individual or entity?
Does the activity involve, or benefit, any listed individuals or entities either directly or indirectly?
Am I inviting a person from a sanctioned country to Canada (or to a third location)?
- Consider indirect dealings with listed persons or entities.
Am I making or receiving a payment to or from a person or entity (either directly or indirectly), or through a bank, in a sanctioned country?
- Is the person invited to Canada doing so?
Am I in any way facilitating a sanctions contravention?

Scenario 1 - Canadian University A screens a faculty candidate B against the UN and Canadian Consolidated Sanctions lists and does some research about the candidate. University A discovers that faculty candidate B previously studied at listed university C and recent publications reveal that B is now part of a research group funded by C. In this example, B is dealing with a listed entity (C), which indicates a potential sanctions circumvention for A.

Activities or transactions that are prohibited by sanctions legislation and relevant regulations

Review sanctions legislation and the relevant regulations to determine if the proposed activity is permitted. For example, the Special Economic Measures (Russia) Regulations and the Special Economic Measures (Iran) Regulations contain many goods and services prohibitions that:

prohibit the sale or supply of many goods and technologies, including dual-use goods that may be used in the manufacture of weapons
prohibit services, including market research, research and development, scientific and technical assistance, (including transferring know-how) etc.

Questions to consider:

Does the activity involve the import or the export of prohibited goods?
Does the activity involve the provision of prohibited services to a listed individual or entity (even indirectly), and/or the provision of prohibited technical assistance or technical data?
Would technical advice, training or assistance be provided to someone with a connection to a sanctioned country, where technical prohibitions are in place? For example:
- Is the individual from, previously lived in, or recently traveled to these sanctioned countries or regions?
- Was the individual's prior education or research conducted at institutions in these sanctioned countries?
- Did the individual participate in research programs, conferences, or collaborations involving institutions or individuals from these sanctioned countries, or those known to have ties with sanctioned countries or listed entities?
- Is the individual involved in research fields that are sensitive or dual use in nature, such as nuclear technology, advanced weaponry, or cybersecurity, or those deemed to be a sensitive technology research area?
- Has the individual received financial support or scholarships from entities or governments in sanctioned countries, or those with known ties to sanctioned countries or listed entities?
- Is the individual a member of academic or professional networks linked to sanctioned countries or listed individuals or entities, or does the individual have personal connections, including family members or close associates, who are members of such networks or are citizens of or reside in sanctioned countries?
- Has the individual been previously employed or had internships with listed entities?
Would any technical advice, training or assistance relate to the manufacture, maintenance or use of an “export listed good”?
- This question may be informed by:
  - checking whether the good is an 'export listed good' as defined under the relevant sanctions regulations for the sanctioned country; and
  - checking whether the advice, training, or assistance would assist with or relate to the manufacture, maintenance or use of the goods.
- Would technical advice, training or assistance increase the sanctioned country's capacity to manufacture, maintain or use those “export listed goods”? Understand the aim of the research project, the impact of the technical advice, training or assistance, and what knowledge already exists in the public domain. For example:
  - Materials science research could be repurposed to improve missile construction or nuclear capabilities. Broader, fundamental research (e.g. basic chemistry or physics without specific industrial or military applications) may pose a lower risk but still requires careful evaluation.
  - Training or assistance may improve the precision or efficiency of manufacturing sensitive technologies, and as such, there is a higher risk that it could enhance the military capabilities of a sanctioned country.
  - New or proprietary technical knowledge not yet in the public domain could pose significant risks if shared, as it might give a sanctioned country, individual or entity an advantage they previously lacked, especially if it relates to dual-use or military technologies.

Scenario 2 - Canadian College D engages in a research collaboration with non-listed foreign academic institution E. At the same time, E engages with listed foreign academic institution F in a similar research area as that of the D-E collaboration. In this instance there may be the possibility of knowledge transfer, indirectly, from D to F.

Red flags

Some individuals and entities may attempt to circumvent Canada’s sanctions through financial transactions. The sanctions due diligence red flags page may be helpful in detecting suspicious transactions. If a transaction raises one or more red flags, there may be a risk of sanctions circumvention or violation. In this case, investigate further and seek legal advice to confirm if the transaction is permissible according to Canada’s sanctions legislation and regulations.

Additional red flags to consider when inviting students, guest lecturers, etc. to Canada:

The individual has a history of transferring or sharing research data with individuals or entities in sanctioned countries.
The individual is or has been involved in activities or public statements that show support for listed individuals or entities, or governments in sanctioned countries.
Publicly available information indicates that the individual has connections with listed individuals or entities, or sanctioned countries.
Irregularities in the individual's visa applications, travel documents, or travel patterns that suggest undisclosed ties to sanctioned countries.

International financial transactions, tuition payments, grants and donations

Accepting donations from listed sources without proper due diligence can expose Canadian academic institutions to compliance risks. Even if the institution did not knowingly solicit funds from listed sources, it has a legal obligation to ensure that financial transactions comply with applicable sanctions requirements.

Scenario 3 - University G receives a large donation through an intermediary foundation H. Verifications reveal that the funds originated from a listed entity I using the foundation H. Despite not knowingly soliciting these funds, University G could face legal and financial risks.

Student recruitment and exchange programs

Institutions must assess the eligibility of students and participants from sanctioned countries for enrollment or participation in exchange programs. There may also be practical impacts of sanctions stemming from banks as listed entities. Students may encounter difficulties in carrying out financial transactions, such as the payment of tuition and undertaking day-to-day activities such as paying rent, buying food, among other things.

Scenario 4 - University J, admits foreign student K. Foreign student K is from a listed academic institution L. While studying in Canada, student K is unable to engage with its home institution L. This includes being prohibited from engaging with L’s administration, K’s former professors, former classmates, etc. Despite the student K not being directly listed, student K’s affiliation with L poses compliance risks. Student K may also face challenges in paying tuition, depending on the regulations that apply to K’s country.

Enforcement

For information on reporting sanctions violations and on penalties for contravening sanctions, see Sanctions compliance and enforcement in Canada.

Contact

For any sanctions inquiries or questions, contact the Global Affairs Canada Sanctions Bureau.

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