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ARTICLE · 03 MARCH 2026

Unpacking Canada's Economic Sanctions Guidance Refresh

McCarthy Tétrault
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Global Affairs Canada ("GAC") has updated its guidance on its interpretation of Canada's economic sanctions and its expectations regarding compliance and due diligence.

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Global Affairs Canada ("GAC") has updated its guidance on its interpretation of Canada's economic sanctions and its expectations regarding compliance and due diligence. These updates include new interpretive guidance for compliance with Canada's sanctions regimes (the "Updated Guidance"), expanded Frequently Asked Questions (the "FAQs"), and limited due diligence and compliance program content.

The Updated Guidance includes sanctions compliance scenarios and reiterates GAC's broad interpretation of the 2023 deemed ownership rule under the Special Economic Measures Act ("SEMA") and Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) ("JVCFOA"). GAC has additionally released sector-specific modules for the academic, financial, real estate, and humanitarian sectors, emphasizing enhanced due diligence, indirect-ownership risks, and rising enforcement expectations, including FINTRAC reporting and new requirements that became effective last

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