On October 13, 2017, Global Affairs Canada published the Consolidated Special Economic Measures Act Sanctions List. This tool provides a list of the individuals and entities subject to sanctions regulations made under the Special Economic Measures Act (SEMA) in Canada. The list refers to the applicable regulations for each individual or entity, which must be consulted on a case-by-case basis to determine the specific prohibitions that apply.
The Consolidated SEMA Sanctions List assists Canadian businesses with ensuring compliance with Canada’s sanctions regime by creating a single point of access containing the names of all of the individuals and entities subject to sanctions regulations.
The Consolidated SEMA Sanctions List was adopted following recommendations of the Parliamentary Standing Committee on Foreign Affairs and International Development that Canada “produce and maintain a comprehensive, public and easily accessible list of all individuals and entities targeted by Canadian sanctions containing all information necessary to assist with the proper identification of those listed”. One of Tereposky & DeRose’s partners, Vince DeRose, testified before the Standing Committee as to the importance for Canadian businesses of creating a consolidated list of individuals and entities subject to sanctions. For more information on the Parliamentary Standing Committee report, see Parliamentary Standing Committee Calls for Improvements in Canada’s Sanctions Regime.
The lawyers at Tereposky & DeRose have significant experience in the design and implementation of sanctions-related compliance programs, including policies, procedures, employee training, and internal control mechanisms. They also regularly assist both Canadian and international businesses, financial institutions, and individuals with internal investigations when “red flags” appear, and provide advice on compliance in these areas. Where breaches have occurred, they have worked closely with their clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada.