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ARTICLE · 17 MAY 2023

Proposed Changes To Canada's Economic Sanctions Laws Create New Challenges And Uncertainty

McCarthy Tétrault
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Businesses should be carefully reviewing their due diligence and screening protocols in light of recently proposed amendments to Canadian economic sanctions laws...

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Terms Of Trade
John Boscariol
John Boscariol
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Martha Harrison
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Robert Glasgow
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Ljiljana Stanic
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Carmen Francis
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Businesses should be carefully reviewing their due diligence and screening protocols in light of recently proposed amendments to Canadian economic sanctions laws regarding dealings with non-sanctioned entities that may have connections to sanctioned parties. Any past determinations from the Canadian government or legal opinions relating to these issues should also be reassessed given these latest developments.

Canada's economic sanctions measures prohibit a number of commercial transactions or relationships known as "dealings" with sanctioned persons known as "Designated Persons". Such prohibitions include dealings in any property that is "owned, held, or controlled by" Designated Persons. With no statutory or administrative guidance available, interpreting the concept of "ownership" in this context has historically been extremely difficult for Canadian businesses and their advisors. Canada is proposing important amendments to sanctions laws which contemplate

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