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When Canadian companies operate across borders, complying with one country's sanctions laws can expose them to prosecution in another. This article examines the unique compliance dilemma that arises when Canadian obligations under the Foreign Extraterritorial Measures Act conflict with U.S. sanctions against Cuba, creating a cross-border compliance trap for businesses with American ties.

Following in the footsteps of the United States and other major trading partners, the Canadian government has been actively pursuing a number of bilateral and regional free trade and investment protection treaties over the past several months.