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ARTICLE · 21 JULY 2023

"Deemed Ownership" Rule Now In Force: Addressing Heightened Canadian Sanctions Risk

McCarthy Tétrault
McCarthy Tétrault
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McCarthy Tétrault

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Major changes to the Canadian economic sanctions regime, the most significant in recent years, are now in force.

CanadaInternational Law
Terms Of Trade
Terms Of Trade
John Boscariol
John Boscariol
Martha Harrison
Martha Harrison
Ljiljana Stanic
Ljiljana Stanic
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Jason Quinn
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Major changes to the Canadian economic sanctions regime, the most significant in recent years, are now in force. On June 22, 2023, the Budget Implementation Act 2023, No. 1 (the "Act") received Royal Assent, bringing into force significant amendments to Canada's autonomous sanctions regime including a new "deemed ownership" rule in the Special Economic Measures Act ("SEMA") and the Justice for Victims of Corrupt Foreign Corrupt Officials Act (Sergei Magnitsky Law) ("Magnitsky Act").

The following provides a brief overview of the amendments and discusses some immediate actions that should be considered in order to address the increased sanctions risk Canadian companies are now facing as a result of the new deemed ownership rule.

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