Canada: Top 10 Canadian Export Controls And Economic Sanctions Developments In H1 2019

Last Updated: July 29 2019
Article by Cyndee Todgham Cherniak

It has been an unusually busy year in Canada for export controls and economic sanctions developments. As a result, we are posting an H1 2019 report on Canadian export controls and economic sanctions developments. The top 10 Canadian export controls and economic sanctions developments in H1 2019 are:

1. Canada will implement the brokering rules on September 1, 2019. Bill C-47 "An Act to amend the Export and Import Permits Act and the Criminal Code (amendments permitting the accession to the Arms Trade Treaty and other amendments)" received royal assent on December 13, 2018. Section 20 of Bill C-47 (the officer's liability provision) entered into force on December 13, 2019. Order in Council SI-2019-0041 sets September 1, 2019 as the date the other provisions enter into force.

2. Canada will become a State Party to the UN Arms Trade Treaty (ATT) on September 17, 2019. With Bill C-47 entering into force, Canada will be compliant with its obligations under the ATT. See Overview of the Arm's Trade Trade Implementation Package.

3. Canada deposited its instrument of ratification of the ATT on June 19, 2019. See Canada presents it instruments of accession to the Arm's Trade Treaty and Deposition of Canada's instrument of accession to the Arm's Trade Treaty.

4. On June 17, 2019, Canada published regulations to implement obligations in Bill C-47. Canada implemented the Brokering Control List, SOR/2019-220, which establishes the Brokering Control List and identifies goods controlled by Canada's brokering rules. The Brokering Control List enters into force on September 1, 2019.

On June 17, 2019, Canada published the Brokering Permit Regulations, SOR/2019-221, which set out the rules for obtaining brokering permits for goods on the Brokering Control List. The Brokering Permit Regulations enter into force on September 1, 2019.

On June 17, 2019, Canada published the Regulations Specifying Activities that Do Not Constitute Brokering, SOR/2019-222, which sets out what activities are not subject to the brokering rules. These regulations enter into force on September 1, 2019.

On June 17, 2019, Canada published General Brokering Permit No. 1, SOR/2019-229, which creates a General Permit that can be used to broker in pre-defined, lower-risk circumstances (and to listed low-risk countries) and establishes conditions for use of the General Brokering Permit. These regulations enter into force on September 1, 2019.

5. On June 21, 2019, Canada imposed economic sanctions against 9 Nicaraguan officials for systematic gross human rights abuses. See Canada Imposes Unilateral Economic Sanctions Against Nicaraguan Officials. Canada promuglated the Special Economic Measures (Nicaragua) Regulations setting out the specific economic sanctions and trade restrictions.

6. On June 25, 2019, Canada published amendments to its economic sanctions against Yemen. Regulations Amending the Regulations Implementing the United Nations Resolution on Yemen, SOR/2019-250 updated Canada's economic sanctions to ensure consistency with the United Nations Sanctions and Canadian law.

7. On June 25, 2019, Canada published amendments to its economic sanctions against Ukraine. Regulations Amending the Special Economic Measures (Ukraine) Regulations, SOR/2019-248 corrected the misspelling of Aleksey Vladimirovich SHATOKHIN. On March 15, 2019, Canada amended the Special Economic Measures (Ukraine) Regulations and by ways of the Regulations amending the Special Economic Measures (Ukraine) Regulations, SOR/2019-72 added 89 designated persons against whom economic sanctions and trade restrictions are imposed.

8. On June 25, 2019, Canada published amendments to its economic sanctions against Venezuela. Regulations Amending the Special Economic Measures (Venezuela) Regulations, SOR/2019-283 removed Manuel Ricardo Cristopher Figuera from the list of designated persons.

On April 15, 2019, Canada amended its unilateral economic sanctions and trade restrictions under the Special Economic Measures (Venezuela) Regulations to add 43 designated persons (see Regulations Amending the Special Economic Measures (Venezuela) Regulations, SOR/2019-106).

9. On April 17, 2019, Canada amended its numbering in the Export Control List, added 19 items for control, removed 8 items from control and made over 300 modifications. As a result, Canada published an Order Amending the Export Control List, SOR/2019-92. Canada also made consequential amendments to 4 General Export Permits.

10. On March 4, 2019, the Canadian government promulgated the Regulations Amending Certain Regulations Made Under the Special Economic Measures Act, SOR/2019-61 to update Canada's unilateral and/or multilateral UN economic sanctions against Burma/Myanmar, Zimbabwe, Iran, Libya, Syria, North Korea, Russia, Ukraine, South Sudan, and Venezuela. The regulations occurred after a review of Canada's sanctions and drafting errors were found. The amendments correct errors and ensure consistency with Canada's economic obligations and between Canadian sanctions laws.

Bonus: Canada indicated that it has launched a criminal investigation into whether Dickens & Madson (Canada) Inc. had violated Canada's economic sanctions against Sudan. It is unusual for Canada to announce criminal investigations by the Royal Canadian Mounted Police. For more information, please refer to Canada investigates whether Canadian lobbying firm breached Sudan sanctions.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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