Canadian sanctions – Essential information
Sanctions are an important part of Canada’s foreign policy toolkit. They are used to foster international peace and security, combat corruption, and promote respect for international norms and values, notably human rights. They form part of a comprehensive foreign policy approach involving political dialogue, engagement at various levels, and programming.
Sanctions apply to Canadians (both in Canada and abroad) and persons (individuals and entities) in Canada, and place restrictions on or prohibit certain activities between Canadians, and persons (individuals and entities) in Canada, and foreign states, individuals, or entities. They can encompass a wide variety of measures, including, but not limited to:
- financial prohibitions
- arms and related materials embargo
- export and import restrictions
- asset freeze
- technical assistance prohibitions
Sanctions applied against foreign states may target specific individuals or entities, specific economic sectors or may apply more broadly, depending on the foreign policy objectives the sanctions seek to achieve.
Disclaimer: The guidance for stakeholders on this page is intended for general informational purposes and does not constitute legal advice. Each topic below addresses complex topics involving sanctions policy, international relations, and domestic and international law. As each circumstance is specific and may engage sanctions in a different way, it is important to carefully review the applicable sanctions regulations before conducting any activities. We recommend that you seek legal counsel for assistance in the interpretation of Regulations. Contravening sanctions is a criminal offence. This information and guidance are presented in alignment with the Cabinet Directive on Regulation.
On this page
- Canadian sanctions legislation
- Canadian sanctions measures
- Permits and certificates
- Sanctions implementation process
- Due diligence practices for compliance with Canada’s sanctions
- Common scenarios or questions
- Canada’s sanctions regime vs other jurisdictions
- Sanctions compliance and enforcement in Canada
- Thematic guidance
Canadian sanctions legislation
Canada has the ability to impose autonomous sanctions under 2 pieces of legislation:
Canada uses autonomous sanctions as a discretionary tool of foreign policy to influence behaviour. The goal is to foster international peace and security, combat corruption, and promote respect for international norms and values, including human rights. Through the use of targeted sanctions measures, Canada strives to minimize adverse consequences for civilian populations and for legitimate business, humanitarian, or other activities.
In addition to autonomous sanctions, Canada also enacts multilateral sanctions. If the United Nations Security Council (UNSC) determines that an act of aggression or a threat to, or breach of, the peace has occurred, it may decide what measures member states shall take to restore or maintain international peace and security. As a member of the United Nations, Canada is legally required to implement the multilateral sanctions imposed by the United Nations Security Council and does so under the United Nations Act.
Circumstances under which the 3 acts may be used:
Special Economic Measures Act
The Special Economic Measures Act (SEMA) allows Canada to impose autonomous sanctions against foreign states, individuals or entities related to that foreign state, in response to any of the following circumstances:
- When an international group that Canada is part of asks its members to take economic actions against another country;
- a grave breach of international peace and security has occurred resulting in, or is likely to result in, a serious international crisis;
- gross and systematic human rights violations; and,
- acts of significant corruption.
Justice for Victims of Corrupt Foreign Officials Act
The Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) allows Canada to impose autonomous sanctions directly against foreign nationals who are responsible for, or complicit in:
- gross violations of internationally recognized human rights against individuals who are promoting or defending human rights; and
- acts of significant corruption.
United Nations Act
If the United Nations Security Council (UNSC) determines that an act of aggression, or a threat to, or breach of the peace, has occurred, it may decide measures that member states shall take to restore or maintain international peace and security.
Canada is legally required to implement sanctions imposed by the UNSC domestically and does this through the United Nations Act (UNA).
For information about the sanctions Canada has imposed against a certain foreign state, individual, or entity, always consult the relevant piece of legislation and regulations. Regulations made under the Special Economic Measures Act, the United Nations Act, and the Justice for Victims of Corrupt Foreign Officials Act may be found on the respective act webpage, as well as on the Current sanctions imposed by Canada page.
You may also consult the Canadian sanctions legislation page.
Canadian sanctions regulations
In Canada, sanctions are enacted through regulations, which are statutory instruments made under an Act of Parliament.
The three Acts provide the legal foundation for Canadian sanctions, while the sanctions regulations, created under these Acts, detail the specific prohibitions that apply to each sanctions regime. The contravention of these regulations can result in criminal charges and lead to penalties as prescribed by the legislation. The regulations define the scope of the measures being imposed including any applicable exceptions. Regulations vary widely and can be updated (amended) to include new prohibitions at any time. For information about the sanctions Canada has imposed, you may consult the relevant regulations on a regular basis.
The regulations contain key information, such as:
- Types of sanctions measures, including details of prohibitions and other measures
- Names of listed individuals and entities (Canadian Consolidated List and UN)Footnote 1
- Exceptions for certain kinds of activitiesFootnote 2
Regulations made under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, and the United Nations Act are on the Justice Laws website. Regulations are listed with the most recent version at the top of the list.
They are also accessible under the “Selected documents” section of the regime-specific sanctions pages found on the Current sanctions imposed by Canada page.
Other Canadian laws
Certain activities may violate other Canadian laws, beyond Canada’s sanctions legislation. In addition to complying with Canada’s sanctions, persons (individuals or entities) in Canada and Canadian persons outside Canada must also comply with other Canadian laws that restrict or impose limits on certain activities with foreign states or foreign nationals.
- The Criminal Code enables Canada to apply measures in relation to terrorist entities, including those not necessarily listed by the United Nations Al-Qaida and Taliban Regulations or the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.
- Regulations enacted under the Export and Import Permits Act (EIPA) provide Canada with an additional mechanism for controlling the flow of military and dual-use goods and technologies contained in specified lists provided for under the EIPA.
- Notably, the export or transfer of any goods or technology to countries named in the Area Control List must be authorized via an export permit issued by the Minister of Foreign Affairs under the authority of the Export and Import Permits Act.
- For more information see Export and import controls.
- The Freezing Assets of Corrupt Foreign Officials Act allows Canada to freeze the assets or restrain the property of certain politically exposed foreign persons (such as government officials or politicians), at the request of a country undergoing internal turmoil or political uncertainty.
- The Immigration and Refugee Protection Act provides the authority to deny entry into Canada to foreign nationals who are inadmissible pursuant to sanctions.
- The Proceeds of Crime (Money Laundering) and Terrorist Financing Act allows Canada to detect and deter money laundering and terrorist financing which supports the enforcement of sanctions.
Other jurisdictions
In addition to requiring compliance with Canadian sanctions legislation, Canadians and Canadian businesses located or operating in other jurisdictions should familiarize themselves to local laws including approved sanctions framework and legislation. For more information see Canada’s sanctions regime vs other jurisdictions.
Canadian sanctions measures
Sanctions place restrictions on activities permissible between Canadians, and foreign states, individuals, and entities.
All individuals listed under SEMA, JVCFOA and UNA (as specified by the relevant regulations) are rendered inadmissible to Canada under the Immigration and Refugee Protections Act.
Measures may include:
Dealings prohibition and asset freeze
Targeted designations of persons (individuals or entities) results in a dealings prohibition. This prohibition bans Canadian persons abroad and persons in Canada from transacting with listed persons, making any goods available to them, or providing services to their benefit. As part of this prohibition, listed persons are effectively subject to an asset freeze, aimed at preventing listed persons from gaining access to property or other assets. For more information, see Dealings prohibition and asset freeze.
Financial prohibitions
Financial prohibitions restrict financial transactions and services, such as foreign investments, acquisitions, wire transfers, or letters of credit.
Export and import restrictions
Export and import restrictions prohibit buying, selling, or shipping identified goods, commodities, services, or technologies to or from a targeted country. For more information, see Export and import restrictions.
Note: When in place, sanctions export and import restrictions are separate from broader export and import controls under the Export and Import Permit Act.
Arms embargos
Arms embargos prohibit exporting and importing of arms and related materials to and from a targeted country and may also prohibit communicating technical data or financial transactions related to military activities.
Technical assistance prohibition
Technical assistance prohibition linked to the products, services, commodities, or technologies subject to the export prohibitions.
Note: There can be other restrictions or prohibitions depending on the Regulation.
For example, the Special Economic Measures (Russia) Regulations (the “Russia Regulations”) contain various sectoral restrictions, such as in the shipping and aircraft/aviation sector as well as export and import restrictions, including on specified goods and technologies. The Russia Regulations prohibit, amongst others:
- any ship registered in Russia or used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia or a listed person from docking in Canada or passing through Canadian waters.
- the provision of all insurance, reinsurance, and underwriting services for aircraft, aviation and aerospace products either owned by, controlled by, registered to, chartered by, or operated by entities and individuals resident, incorporated, or domiciled in Russia.
- exporting, selling, supplying or shipping any good described in the Restricted Goods and Technologies List. This includes a broad range of items in the areas of electronics, computers, telecommunications, sensors and lasers, navigation and avionics, marine, aerospace and transportation.
- the export or import, selling, purchasing or acquiring, as well as the supplying or shipping of any luxury good referred in the Russia Regulations, wherever situated, to or from Russia or to or from any person in Russia.
See SEMA Russia Regulations for the complete list of measures.
Permits and certificates
If a planned activity or transaction is determined to be prohibited under Canadian sanctions, consider applying for a permit or certificate.
Granted on an exceptional, case-by-case basis, and at the discretion of the Minister of Foreign Affairs, these can allow for specific activities or transactions that would otherwise be prohibited by sanctions regulations to be carried out. While permits are granted in relation to sanctions prohibitions under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act, certificates are granted in relation to sanctions prohibitions under the United Nations Act.
See Permits and Certificates to learn how to apply and what documents are required to complete an application.
Note: Global Affairs Canada does not provide legal advice to the public. We cannot confirm whether or not your particular situation requires a permit or certificate prior to receipt of a formal application. If you are unsure whether or not your proposed activity or transaction is prohibited, consult the relevant regulations for each country. If necessary, seek the advice of private legal counsel before applying for a permit or certificate.
There is no guarantee that your application for a permit or certificate will be approved. Furthermore, Global Affairs Canada cannot provide specific timelines for a Ministerial response to an application.
Contravening sanctions is a criminal offence. Do not undertake any activities prohibited by sanctions until you have received a signed permit or certificate.
Sanctions implementation process
Under Canadian sanctions legislation, the Minister of Foreign Affairs has the authority to recommend to the Governor-in-Council the imposition of sanctions. The Sanctions Bureau at Global Affairs Canada coordinates the development of sanctions measures. Additional Global Affairs Canada and government departments may be engaged or consulted whenever required.
Canada is judicious when imposing sanctions and is committed to their effective and coordinated use when appropriate. Canada’s foreign policy toolbox includes sanctions as a key component, but not exclusively, of Canada’s commitment to playing a leadership role in preserving and strengthening an international rules-based order. Sanctions constitute a key component of Canada’s commitment to playing a leadership role in the preservation and strengthening of an international rules-based order. Canada has established a due diligence process to consider and evaluate possible cases of human rights violations, corruption or other circumstances that may warrant the use of sanctions. Canada also considers the broader political and international context when deciding whether sanctions or any other tools in Canada’s foreign policy toolbox may be an appropriate response.
Sanctions entry into force
Unless otherwise specified in the relevant Regulations, sanctions prohibitions apply from the date of their entry into force. In some cases, some prohibitions may include ‘wind-down periods’, meaning they only take effect after a specified period following the date of their entry into force. Further, exceptions may apply for certain activities or situations. The relevant Regulations will specify whether any wind-down periods or exceptions apply.
For example, under the Special Economic Measures (Russia) Regulations, in the case of a contract with a listed person that was entered into before the date the person was listed, it is permissible to discharge contractual obligations such as receiving certain payments, in whole or in part, provided that no payment is made to or for the benefit of a listed person.
The following scenarios may serve as illustrative examples of entry into force provisions for activities pursuant to the Special Economic Measures (Russia) Regulations:
Scenario 1
A Canadian company (“A”) has entered into a contract with a non-listed Russian company (“B”). As per the contract, A sends funds to B in return for the delivery of non-prohibited goods. After the transaction took place, company B is listed under Schedule 1 of the Special Economic Measures (Russia) Regulations and is thus subject to the dealings ban. At the time that the designation came into force, the goods provided by B had already been delivered to A and payment had already been made.
The financial transaction between company A and company B would not be considered to have contravened the dealings ban because it was completed prior to the coming into force of B’s designation. Similarly, the goods that A purchased from B were delivered prior to the coming into force of B’s designation, so A may use and dispose of the goods without engaging the dealings prohibitions.
Scenario 2
A Canadian company (“A”) has entered into a contract with a non-listed Russian company (“B”). As per the contract, A sends funds to B in return for the delivery of non-listed goods. After the transaction took place, company B is listed under the Special Economic Measures (Russia) Regulations and is thus subject to a dealings ban. At the time that the designation came into force, payment had been made but the goods provided by B had not yet been delivered.
The financial transaction between company A and company B is not considered to have contravened the dealings prohibitions because it was completed prior to the coming into force of B’s designation. As for the goods: given that company A has already provided payment to company B, and provided that the activity does not require any further dealings with B or benefit it in other ways, company A may receive the goods delivered by B and use them without engaging the dealings prohibitions in accordance with their pre-existing contract.
Scenario 3
A Canadian company (“A”) has entered into a contract with a non-listed Russian company (“B”). As per the contract, A sends funds to B in return for the delivery of non-listed goods. At a given time, company B is listed under the Special Economic Measures (Russia) Regulations and is thus subject to a dealings ban. At the time that the designation came into force, A had not yet fully paid but B had already delivered the goods to A.
Notwithstanding the fact that company A entered into the contract with company B before the latter was listed, any dealings or transactions with company B after the date that the designation came into force would be considered a contravention of the dealings ban because there would be a direct benefit to a listed person.
Due diligence practices for compliance with Canada’s sanctions
Disclaimer: The guidance for stakeholders on this page is intended for general informational purposes and does not constitute legal advice. Each topic below addresses complex topics involving sanctions policy, international relations, and domestic and international law. As each circumstance is specific and may engage sanctions in a different way, it is important to carefully review the applicable sanctions regulations before conducting any activities. We recommend that you seek legal counsel for assistance in the interpretation of Regulations. Contravening sanctions is a criminal offence.
Due diligence refers to reasonable steps taken to assess whether entering into a particular relationship or engaging in an activity is likely to violate Canadian autonomous or UN sanctions. Canadian individuals and entities are advised to conduct due diligence before engaging in an activity abroad or engaging in transactions involving individuals or entities from foreign countries.
The goal is to identify whether an activity is likely to involve a violation of Canadian or UN sanctions. The following general questions are a non-exhaustive list of examples to help assess whether your intended activity may be prohibited under Canadian autonomous sanctions or UN sanctions:
Examples of due diligence guiding questions
Question 1
Is my activity taking place in relation to a country or entity subject to Canadian or UN sanctions?
Action: Consult the Canadian sanctions related to the specific country on Current sanctions imposed by Canada. To verify if an entity is subject to sanctions, consult the Consolidated Canadian Autonomous Sanctions List and United Nations Security Council Consolidated List.
Question 2
Does my activity involve, or benefit, any listed individuals or entities (persons), or any entities owned or controlled by listed persons?
- Am I dealing with any listed persons, or companies owned by a listed person?
- Am I inviting a person from a sanctioned country to Canada (or to a third location)?
- Am I making a payment to an individual or entity, or through a bank, in a sanctioned country?
Action: As a first step, screen individuals and entities names against those identified as in the consolidated sanctions lists: Consolidated Canadian Autonomous Sanctions List and United Nations Security Council Consolidated List.
You must also consider indirect dealings. This includes considering any association your proposed activity may have with a listed individual or entity. For example, through:
- subsidiaries of listed entities, parent/holding companies, intermediary banks;
- any persons dealing with a listed individual or entity (such as a family member, associate, foreign client or partner, legal representative, etc.); or
- those acting on behalf of listed individuals or entities.
While the consolidated list may include aliases, it’s important to be cognizant of different spellings and variations in the order of names. When screening for names of individuals and entities, you can search a partial name to find alternative spellings.
Question 3
Are there other activities/transactions that are prohibited in relation to this country?
- Does my activity involve the import or the export of prohibited goods and technologies?
- Does my activity involve the provision of prohibited services to a listed entity, and/or the provision of prohibited technical assistance or technical data?
Action: You may consult the regulations made under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, and the United Nations Act.
You may also consult other Canadian laws that restrict or impose limits on certain activities with foreign states or nationals, including:
- The Export and Import Permits Act, for export and import restrictions for military and dual-use goods and technologies listed on the Export Control List.
- The Criminal Code, for measures applied in relation to terrorist entities; and
- The Freezing Assets of Corrupt Foreign Officials Act, for restrictions imposed in relation to politically exposed foreign persons (such as government officials or politicians) from a country in turmoil.
Question 4
Am I in any way facilitating an activity prohibited by sanctions?
Action: If you’ve answered “yes” to any of the previous questions, there is the risk that your activity or transaction may contravene sanctions and you need to seek legal counsel.
Question 5
Does my subsidiary company operating in a foreign country ensure compliance with both Canadian legislation and the foreign country’s laws?
- Does my subsidiary company have direct or indirect dealings with individuals or entities (persons) listed under Canadian sanction laws (SEMA, JVCFOA, UNA) and the foreign jurisdiction’s laws?
Action: Canadian entities operating abroad are subject to Canada’s sanctions legislation. There may also be restrictions or prohibitions in the country in which the subsidiary is operating. The subsidiary must consult both Canada’s and the foreign jurisdiction’s laws and regulations. Compliance with another country’s sanctions legislation does not ensure compliance with Canadian law, and vice versa.
Common scenarios or questions
Can I do business with a country subject to Canadian sanctions?
The ability to do business with an individual or entity in a country or regime subject to Canadian sanctions will depend on the specific measures in place.
Sanctions can impact Canadian businesses, individuals or entities (persons) in Canada by:
- prohibiting all or specific types of trade and other economic activities with listed persons in a particular country or regime;
- prohibiting all or specific types of trade and other economic activity with a foreign market;
- restricting financial transactions and services, such as foreign investments, acquisitions, wire transfers, debt financing or letters of credit; or
- freezing or seizing property situated in Canada.
These restrictions may apply to dealings with the entire country, with non-state actors, such as terrorist organizations, or with listed persons (individuals and entities) from that country. It is important to carefully review the regulations made under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, and the United Nations Act before conducting business to determine what prohibitions apply. When in doubt, seek the advice of legal counsel for assistance in the interpretation of regulations. Please note that Global Affairs Canada does not provide legal advice to the public and is unable to confirm whether or not your particular activity or transaction is permitted under Canadian sanctions.
What do I do if a bank has blocked my transaction?
First, contact the financial institution and ask them to provide the reasons for blocking the transaction. Banks and other financial institutions may block, prohibit, or freeze transactions for any number of reasons, including (but not limited to) compliance with sanctions regulations in Canada or abroad.
If the proposed transaction is blocked for reasons of institutional policy and the institution advises you that an economic sanction prohibits the transaction, you may wish to follow up further with the financial institution.
If the proposed transaction is blocked for reasons of institutional policy, you may wish to follow up further with the financial institution.
If the institution advises you that an economic sanction prohibits the transaction, request that they provide the specific regulatory provision(s) blocking the transaction.
If the transaction has been blocked due to a Canadian sanctions regulation, you may wish to review the relevant regulation and/or seek the advice of legal counsel to determine if an exception applies or if the transaction is indeed prohibited.
If you conclude that the intended transaction was prohibited at the time it took place, you may consider applying for a permit or certificate, which can allow for specific activities or transactions that would otherwise be prohibited by sanctions to be carried out on an exceptional basis and at the discretion of the Minister of Foreign Affairs. Information on how to apply and what documents are required to complete an application is available on our Permits and Certificates page.
If the financial transaction has been blocked to comply with foreign laws, you may wish to seek the advice of legal counsel in the relevant foreign state regarding next steps. It is important to note that a transaction may have engaged both Canadian laws in the laws of other foreign jurisdictions. In such cases, you may need to engage with both Canadian authorities and those in the other relevant foreign state.
Can I deal with the subsidiaries of a listed company?
Under the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA), property owned by an entity that is in turn owned or controlled by a listed individual or entity is subject to the dealings ban defined under the relevant Regulations.
The SEMA and the JVCFOA include 3 criteria by which ownership and control may be assessed:
- if the listed person holds, directly or indirectly, 50% or more of the shares or ownership interests in the entity or 50% or more of the voting rights in the entity;
- if the listed person is able, directly or indirectly, to change the composition or powers of the entity’s board of directors; or,
- if it is reasonable to conclude, that the listed person is able, directly or indirectly and through any means, to direct the entity’s activities.
Should any of these provisions apply, the non-listed entity’s property would be regarded as owned or controlled by the listed individual or entity, and it would therefore be prohibited for Canadian persons abroad or persons in Canada to deal in the property of that individual or entity even if they are not themselves listed under Canadian sanctions.
The following scenarios may serve as illustrative, but non-exhaustive, examples for activities pursuant to the SEMA and the JVCFOA:
Scenario 1
A Canadian company is considering the possible sanctions implications of buying goods from a subsidiary of a listed entity. The listed parent company owns a majority of shares in the subsidiary. Given that one of the deemed ownership provisions apply, the subsidiary would be deemed to be owned or controlled by the listed parent company with respect to the dealings bans under the SEMA and the JVCFOA. Consequently, it would be prohibited for the Canadian company to purchase goods from the subsidiary.
Scenario 2
A Canadian company is considering the possible sanctions implications of buying goods from a subsidiary of a listed entity. While the listed parent company does not meet the 50% or more ownership criteria of the subsidiary, it is known to exercise considerable influence over its strategic decision-making. Given that at least one of the deemed ownership provisions applies, the subsidiary would be deemed to be owned or controlled by the listed parent company. Consequently, it would be prohibited for the Canadian company to purchase of goods from the subsidiary.
Scenario 3
A Canadian company exports dual-use technology and ships it through a freight company that resells goods to a foreign company from a non-sanctioned country. The company purchasing the goods is owned by a shell company. One of the board members of the shell company happens to be an individual listed under Canada’s sanctions. Even though the freight company oversees the transaction in the foreign country, the Canadian seller is responsible to conduct its risk assessment of the beneficial end-user. Consequently, it would be prohibited for the Canadian company to pursue this transaction as it results in a prohibited dealing, even though it is indirect. Freight companies must also respect Canada’s sanctions if transporting goods from Canada and should ensure the seller of the goods has undertaken appropriate due diligence to ensure the sale respects Canadian law.
Can I deal with an entity that deals with a listed person?
Under most Regulations made pursuant to the Special Economic Measures Act 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 – even indirectly, such as through a third party – including if that third party is not Canadian and/or is located outside of Canada.
For example, Section 3 paragraph (b) of the Special Economic Measures (Russia) Regulations prohibits the direct or indirect facilitation of dealings between any person and a listed person.
As such, knowingly entering into or facilitating a transaction related to a dealing between any person and a listed person would be prohibited under the Special Economic Measures (Russia) Regulations. This prohibition applies regardless of whether the third party is Canadian or situated in Canada, or whether or not any sanctions apply to this third party.
It is important to check the relevant Regulations to determine whether a prohibition may apply.
A “dealing in property” may apply to real property (for example, but non-exhaustive, land or buildings), as well as all other forms of property, including physical goods – such as equipment, vehicles, and artwork – or intangible property – such as money, financial instruments, and intellectual property.
The following scenario may serve as one possible illustrative example for an activity pursuant to the Special Economic Measures (Russia) Regulations:
Scenario 1
A Canadian company (“A”) is the end-user of a type of product that it purchases from a non-listed foreign supplier (“B”). Company B manufactures this product using materials that it sources directly from a company listed under the Special Economic Measures (Russia) Regulations (“C”).
While a foreign supplier is not subject to Canadian sanctions and it may be legal for B to deal with C in jurisdictions outside of Canada, transactions between Canadian company A and foreign supplier B involving company’s C products are nonetheless considered prohibited under the Special Economic Measures (Russia) Regulations unless an exception is applicable. It would therefore be prohibited for the Canadian end-user company, A, to continue procuring goods from B that involve dealings with C past the date on which the listing of C came into force.
Canada’s sanctions regime vs other jurisdictions
There are often significant differences in how countries impose sanctions, due to their different legal systems. Canada’s sanctions are applied under Canadian law, which determines the legal basis upon which the sanctions are made, as well as the specific prohibitions that are imposed.
Compliance with another country’s sanctions legislation does not ensure compliance with Canadian law, and vice versa. Canadian sanctions restrictions must be respected by any Canadian and persons in Canada. Canadian persons (both individuals and entities) must also comply with Canadian sanctions restrictions when they are located or engaged in activities abroad. Always consult the Canadian regulations to determine if any Canadian sanctions measures apply to your situation.
If you are located in, or have dealings in, a foreign jurisdiction, be sure to consult that jurisdiction’s laws and regulations to determine if any additional sanctions measures might apply to your intended activity and/or transaction. If you are planning to undertake a prohibited activity, you may require a license or permit from other jurisdictions, in addition to a Canadian sanctions permit or certificate.
Sanctions do not apply in the same way to every country. For Canadian sanctions, you may consult the regulations made under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, and the United Nations Act on the Justice Laws website. Regulations are listed with the most recent version at the top of the list. They are also accessible under the “Selected Documents” section of the regime-specific sanctions pages that you may find on the current sanctions imposed by Canada page.
If necessary, seek the advice of legal counsel to determine whether any Canadian sanctions measures apply to your situation.
Sanctions compliance and enforcement in Canada
Canadian sanctions restrictions must be respected by any Canadian, as well as by all persons (both individuals and entities) in Canada, including governmental institutions. Canadian persons (both individuals and entities) must also comply with Canadian sanctions restrictions when they are located or engaged in activities abroad.
Contravening sanctions is a criminal offence, enforced by the Canada Boarder Services Agency (CBSA) and the Royal Canadian Mounted Police (RCMP). Financial intelligence produced by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) can support CBSA and the RCMP investigations.
The CBSA enforces Canada’s export controls and sanctions regime by assessing risk, detaining and examining goods and regulating the trade of goods prohibited by sanctions. It also supports criminal investigations and prevents listed individuals from entering Canada.
The CBSA and the RCMP have a shared responsibility for investigating criminal sanctions evasion. The RCMP is the main point of contact to receive and maintain the information as it relates to self-reporting.
In addition, FINTRAC is responsible for the supervision of certain businesses in Canada as it pertains to reporting of suspected sanctions evasion. FINTRAC produces tactical financial intelligence disclosures for law enforcement and GAC pertaining to suspected sanctions evasion, as well as strategic intelligence products on this topic.
Under the United Nations Act, the maximum penalty on summary conviction is a $100,000 fine or a 1‑year prison term, or both. Convictions on indictment may result in a maximum 10‑year prison term.
Under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act, the maximum penalty on summary conviction is a $25,000 fine or a 1‑year prison term, or both. Conviction on indictment may result in a maximum 5‑year prison term.
Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) are required to report to FINTRAC as soon as practicable after they have taken measures that enable them to establish that there are reasonable grounds to suspect that a transaction or attempted transaction is related to the commission of a sanctions evasion offence. Every person or entity that fails to report is guilty of an offence and liable on summary conviction to a fine of not more than $1,000,000, as per S. 77(1) of the PCMLTFA.
Separate penalties are imposed for contraventions of the Criminal Code, the Freezing Assets of Corrupt Foreign Officials Act and the Export and Import Permit Acts.
How to report sanctions violations or evasion
To report sanctions violations by individuals or entities to the CBSA, use the CBSA Online Tip Submission.
To report sanctions violations to the RCMP, or to disclose and report property and transactions related to targeted individuals and entities, contact:
Federal Policing Intake
RCMP
73 Leiken Drive
Ottawa, Ontario
Canada K1A 0R2
Fax: 613-825-7030
Email: Sanctions_Intake-Triage@rcmp-grc.gc.ca
Please note that your information is not protected via email. If necessary, you may submit an encrypted email or send a secure fax.
If you are a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and want to report sanctions evasions, please fill out the FINTRAC web form.
Thematic guidance
Thematic guidance provides additional information to help navigate the sanctions framework and legislation. It includes information on compliance and best practices to support enhanced due diligence.
- Oil and petroleum sector
- Financial activities
- Import/Export restrictions and customs notices
- Information Technology (IT) sector
- Research security
Oil and petroleum sector
- 2025-09-03 – Canada strengthens oil price cap measures to curb Russian war revenues
- 2024-10-21 – Global Advisory – Updated Price Cap Coalition Advisory for the Maritime Oil Industry and Related Sectors: Best Practices in Response to Recent Developments in the Maritime Oil Trade
- 2024-06-21 – Bulletin – Oil price cap (OPC) compliance and enforcement - SSB No.: 18/2024
- 2024-02-01 – Global Alert - Oil Price Cap Coalition Compliance and Enforcement Alert
- 2023-12-20 – Global Advisory - Statement of the G7 and Australia on Price Cap Rule Updates for Seaborne Russian-Origin Oil and Petroleum Products
- 2023-10-12 – Statement - Statement from the G7 and Australia on Actions Taken to Enforce Price Caps for Seaborne Russian-Origin Oil and Petroleum Products
- 2023-10-12 – Global Advisory - Global Advisory for the Maritime Oil Industry and Related Sectors on Best Practices in Response to Recent Developments in the Maritime Oil Trade
Financial activities
- 2025-08-22 – Report - 2025 Assessment of Money Laundering and Terrorist Financing Risks in Canada: Report
- 2025-07-11 – Special Bulletin - Special Bulletin on financial activity associated with evasion of counter proliferation sanctions
- 2025-06-01- FATF Report - Complex Proliferation Financing and Sanctions Evasion Schemes (PDF)
- 2025-02-10 - FINTRAC Compliance Guidance - Report suspected sanctions evasion
- 2024-10-23 – Special Bulletin - Special Bulletin on the use of the legal profession in money laundering and sanctions evasion
- 2024-06-25 – Special Bulletin - Special Bulletin on financial activity associated with suspected sanctions evasion
- 2024-03-22 – Joint Financial Intelligence Advisory - Joint financial intelligence advisory: illegal procurement of dual-use goods by Russian end-users
- 2023-07-17 – FINTRAC Advisory - FINTRAC advisory: Financial transactions related to countries identified by the Financial Action Task Force
- 2023-03-09 - Global Advisory - Global Advisory on Russian Sanctions Evasion Issued Jointly by the Multilateral REPO Task Force
- 2021-11-19 – FINTRAC Red Flags - Money laundering and terrorist financing indicators—Financial entities
Import/Export restrictions and customs notices
- 2025-07-03 – Customs Notice - Customs Notice 22-01: New Sanctions and Export Controls in Response to Russia's Invasion of Ukraine
- 2024-09-24 – G7 Global Advisory - Preventing Russian Export Control and Sanctions Evasion: Updated Guidance for Industry
- 2024-03-01 – Customs Notice - Customs Notice 24-05: New Sanctions under the Regulations Amending the Special Economic Measures (Russia) Regulations – Importation of Diamonds
- 2023-09-26 – Reference - High priority items list subject to export controls
- 2022-03-03 – Sanctions Memorandum of Canadian Border Service Agency - Memorandum D19-11-1 - Canadian Economic Sanctions
- 2022-02-24 – Custom Notice - Customs Notice 22-01: New Sanctions and Export Controls in Response to Russia’s Invasion of Ukraine
Information Technology (IT) sector
- 2025-07-16 – Advisory - Advisory on North Korean information technology (IT) workers | Royal Canadian Mounted Police
Research security
- 2024-12-13 – Guidance on Safeguarding Your Research - Guidelines and Tools to Implement Research Security
Additional resources
Consult international and related resources on sanctions compliance and best practices to support enhanced due diligence.
International resources
- US – OFAC Sanctions Compliance Process Framework (PDF)
- UK – Strategic Export Controls
- UK – Export controls applying to academic research
- UK – Countering Russian Sanctions Evasion - Guidance for Exporters
- EU - Sanctions Due Diligence: Where to Begin
- EU – Red Flags: Mastering the Indicators of Sanctions Risk
- EU – Guidance Against Russia Sanctions Circumvention
- Australia – Guidance on Sanctions Compliance
Related links
Open Source Centre provides open and public accessible cutting-edge research products on global security challenges faced by the United Kingdom and its allies like Canada.
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