Emergency Order – Impact On Insurers

Today, the Government of Canada released regulations made pursuant to the Emergencies Act following its declaration of the Emergency Economic Measures Order (the "Order") on February 14, 2022. The Order applies to numerous financial institutions, including:

• authorized foreign banks under the Bank Act;
• credit unions under the Cooperative Credit Associations Act;
• companies, foreign companies, and societies under the Insurance Companies Act;
• trust and loan companies; and
• companies that facilitate electronic transactions specified in the Order.¹

Among other things, the Order provides that these entities must cease:

1. dealing in any property, wherever situated, that is owned, held or controlled, directly or indirectly, by a designated person or by a person acting on behalf of or at the direction of that designated person;