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ARTICLE · 29 OCTOBER 2026

Canada Clarifies Sanctions Control Tests: Compliance Implications For Canadian Businesses

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Global Affairs Canada (GAC) has issued new guidance on the deemed ownership rules under Canada’s sanctions laws. These rules establish circumstances in which a company that is not sanctioned is deemed to be controlled by a sanctioned person, such that the company's property is treated as the property of the sanctioned person and subject to a dealings prohibition.

CanadaInternational Law
Clifford Sosnow
Clifford Sosnow
Christopher Little
Christopher Little
Olivia Elliot
Olivia Elliot
Rachel Loif
Rachel Loif
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Global Affairs Canada (GAC) has issued new guidance on the deemed ownership rules under Canada’s sanctions laws. These rules establish circumstances in which a company that is not sanctioned is deemed to be controlled by a sanctioned person, such that the company's property is treated as the property of the sanctioned person and subject to a dealings prohibition.

As such, the guidance will have significant implications for Canadian businesses complying with Canadian sanctions.

We discuss the guidance and its implications below.

Background: Canada’s Deemed Ownership Framework

Canada’s sanctions laws prohibit persons in Canada and Canadians abroad from dealing in property that is owned, held or controlled, directly or indirectly, by sanctioned persons.

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