On June 21, 2024, Canada announced additional sanctions under the Special Economic Measures (Haiti) Regulations (the “Haiti Regulations”). Canada has sanctioned three “Haitian gang leaders” to address “the escalating gang violence in Haiti, which continues to have devastating effects on the Haitian population”. Canada has stated it has reason to believe that the listed individuals “have engaged in activities that have undermined the peace, security and stability of Haiti and that have contributed to acts of gross and systematic human rights violations in Haiti”.

The Haiti Regulations freeze any Canadian held assets of the sanctioned individuals.  The individuals are also now inadmissible to Canada under the Immigration and Refugee Protection Act.  Since November 2022, Canada has imposed sanctions against 31 individuals under the Haiti Regulations.

We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.

Authors: Michelle Folinas and Maria Mateus.

Should you have any questions regarding these developments or sanctions generally, please contact: