ARTICLE · 03 OCTOBER 2024

Changes To Canada's Sanctions Enforcement Regime

Tereposky & DeRose

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In an effort to combat sanctions evasion, on August 19, 2024, recent amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act ("PCMLTFA") and its regulations came into force...

CanadaGovernment, Public Sector

Stephanie Desjardins

In an effort to combat sanctions evasion, on August 19, 2024, recent amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act("PCMLTFA") and its regulations came into force, expanding the reporting obligations for "reporting entities"

The recent amendments include a newly created "sanctions evasion offense" under the PCMLTFA, which is defined as:

an offence arising from the contravention of a restriction or prohibition established by an order or regulation made under the United Nations Act, the Special Economic Measures Act or the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

The amendments expand the existing reporting requirement for transactions where there are reasonable grounds to suspect the transaction is related to money laundering or terrorist financing to include sanctions evasion, as well. Reporting entities are now required to report suspicious transactions to the Financial Transactions and

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