Article
Canadian Sanctions Alert: Your Counterparty May Be Subject To Sanctions Even If It Is Not Designated
Global Affairs Canada has issued comprehensive guidance on Canada's "deemed ownership" rules under sanctions law, clarifying when companies not directly designated may still be subject to sanctions restrictions due to ownership or control by designated persons. The guidance addresses three distinct control tests—including ownership thresholds, board control, and de facto influence—and provides practical examples of how these provisions apply to complex corporate structures and proxy arrangements

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