Canadian sanctions guidance — Humanitarian sector

This guide is designed to help Canadian charities and non-profit organizations (NPOs) understand sanctions compliance and to manage sanctions risks. The information is not exhaustive, as such, it is recommended that each institution ensure they 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.

On this page

• Overview
• Due diligence
• Red flags
• Enforcement
• Contact

Overview

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

Canadian charities and NPOs undertake extensive work globally. Canada has sanctions in place in some jurisdictions where Canadians and those in Canada undertake humanitarian efforts. Canada’s sanctions are put in place in response to a variety of factors but are not intended to impede the supply of humanitarian aid. Canadian charities and NPOs need to be aware of Canadian sanctions and any potential implications for their work in the delivery of humanitarian assistance and support internationally.

Due diligence

Even though Canadian organizations undertaking humanitarian activities may be well intentioned in providing services supporting basic human needs, it is important to be aware of the risk of sanctions circumvention.

Certain local actors implicated in executing humanitarian projects in sanctioned countries may attempt to circumvent prohibitions through different schemes which may benefit individuals and/or entities listed under Canadian legislation. The purpose of sanctions screening due diligence is not to deny humanitarian assistance to final beneficiaries (i.e. identified individuals in need who would receive funds or material goods for personal use), but to help detect and prevent potential risks of sanctions circumvention.

Canada encourages the effective and robust enforcement of sanctions through rigorous due diligence, which can help assess whether an activity may trigger sanctions or if an activity is an attempt to circumvent Canada’s sanctions. The sanctions compliance program information contains general due diligence best practices. Building awareness by sharing best practices within the sector about challenges, threats, and ways to reduce risks may enhance sanctions compliance.

Canada’s 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.

There are some key considerations when delivering humanitarian assistance:

Transacting with listed persons

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.

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.

For example, it is prohibited to provide financial or related services to an organization owned or controlled by a listed individual or entity, even if the organization provides humanitarian aid or assistance as part of its mandate. The prohibition also applies in situations when a funding recipient or project beneficiary individual or entity enter into transactions or facilitate transactions related to the property, both tangible and intangible, of a listed individual or entity. See Dealings prohibition and asset freeze for more information.

Screening efforts should focus on intermediaries who may receive funds, goods, or services, either directly or indirectly, as part of a proposed project. This includes identifying both direct and indirect associations between all project beneficiaries and funding recipients, and any listed individuals and entities. Intermediaries may include local implementing partners, consultants, suppliers, logistics services providers, and subcontracted local staff. Knowing your partners and beneficial end-users is key to sanctions compliance.

Some questions to consider:

• Does the activity involve, or benefit, any listed individuals or entities?
• Am I dealing with an individual or entity that deals with a listed individual or entity?
  • Does the prospective party to a project or transaction have any connection, even indirectly, with a listed individual or entity?
  • Are there any intermediaries of concern?
  • Are there any indirect dealings with a listed individual or entity through associates, family members, subsidiaries, parent/holding company, intermediary bank, legal representatives, among others?
• Am I inviting an individual from a sanctioned country to Canada (or to a third location)?
• Am I making or receiving a payment to or from an individual or entity (either directly or indirectly), or through a bank, in a sanctioned country? Is the individual invited to Canada doing so?
• Are there connections of concern, such as a history of engagement with legal entities or arrangements that may have a link to listed individuals, entities, elites, government officials, and/or their proxies?
• Am I in any way facilitating a sanctions contravention?

You may also consult the guidance on financial or related services prohibitions.

Restrictions and exceptions

Canadian sanctions regulations often include exceptions to allow for specified activities, such as those of a humanitarian nature. Note that exceptions, like prohibitions, differ from regulation to regulation so it is important to confirm applicable conditions before engaging in any activity. You may assess whether your activities meet the criteria for an exemption under humanitarian assistance. Relevant regulations can be found under each regime (foreign state subject to sanctions).

In some cases, only specified entities such as humanitarian agencies may be permitted to carry out humanitarian activities under such exemption. In those cases, you may be able to conduct your activities as a subcontractor in collaboration with those specified entities under the relevant regulations.

A general permit allows the provision of humanitarian financial and services assistance to Syria is in place until February 2026. At the discretion of the Minister of Foreign Affairs, this general permit may be renewed or removed when it expires. The general permit does not require a permit application. Consult the General permit FAQ for more information.

For activities that are otherwise prohibited in countries where sanctions regulations do not exempt humanitarian assistance, or a partnership with a specified agency is not an option, you may consider applying for a Permit or a Certificate.

Red flags

Some individuals and entities may attempt to circumvent Canada’s sanctions. 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, you may investigate further and seek legal advice to confirm if the transaction is permissible or not according to Canada’s sanctions legislation and associated regulations.

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.