On September 21, 2023, Canada announced further sanctions under the Special Economic Measures (Haiti) Regulations (the “Haiti Regulations”). Canada has sanctioned three elite businessmen, “who are fueling the violence and instability in Haiti by engaging in significant acts of corruption”. Specifically, Canada finds that these individuals have fostered a “climate of impunity” in Haiti, by means of “corruption and other criminal acts and by enabling the illegal activities of armed gangs that terrorize the population”. These sanctions are effective retroactively as of September 20, 2023.

The Haiti Regulations freeze the Canadian held assets of those sanctioned and deem them inadmissible to Canada under the Immigration and Refugee Protection Act. These sanctions form part of Canada’s effort to stop the flow of illicit funds and weapons in Haiti in order to weaken and dismantle criminal enterprises. 

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: Vince DeRose, Jennifer Radford, Stephanie Desjardins, Michelle Folinas, Jack Bowness.