Canada: Consolidated Canadian Autonomous Sanctions List

In November 2023, the Consolidated Canadian Autonomous Sanctions List was added to AEB's portfolio of restricted party lists. Should this list be relevant for your company, and you wish to include it into your AEB Compliance Screening software, the Consolidated Canadian Autonomous Sanctions List can be licensed in addition to your already existing content.

What is the meaning of this restricted party list?

Canada primarily imposes sanctions under three pieces of legislation: 1) the United Nations Act, 2) the Special Economic Measures Act, SEMA, 3) the Justice for Victims of Corrupt Foreign Officials Act, JVCFOA.

The Consolidated Canadian Autonomous Sanctions List includes individuals and entities subject to specific sanctions regulations made under

• The Special Economic Measures Act, SEMA and
• The Justice for Victims of Corrupt Foreign Officials Act, JVCFOA

By issuing regulations based on SEMA and JVCFOA, Canada imposes its autonomous national sanctions which supplement the sanctions of the UN Security Council consolidated in the United Nations Security Council Consolidated List.

Special Economic Measures Act, SEMA

Under SEMA Canada generally enacts its autonomous economic sanctions. Absent a UN Security Council resolution SEMA enables the Canadian government to impose sanctions when:

• an international organization or association of states of which Canada is a member calls on its members to take economic measures against a foreign state;
• a grave breach of international peace and security has occurred and is likely to result in a serious international crisis;
• gross and systematic human rights violations have been committed in a foreign state; or
• a national of a foreign state, who is either a foreign public official or an associate of such an official, is responsible for or complicit in acts of significant corruption.

Justice for Victims of Corrupt Foreign Officials Act, JVCFO

The Justice for Victims of Corrupt Foreign Officials Act came into force on Octoberg 18, 2017. Pursuant to the JVCFOA Canada has imposed targeted measures against foreign nationals who are responsible for or complicit in gross violations of human rights; or are public officials or an associate of such an official, who are responsible for or complicit in acts of significant corruption.

The Consolidated Canadian Autonomous Sanctions List is published by the Department of Foreign Affairs, Trade and Development Canada. The link provides the original list. 

Which companies should screen against the Consolidated Canadian Autonomous Sanctions List?

The screening against this list is obligatory for companies incorporated under or subject to Canadian law. Moreover, other companies may wish to conduct their denied party screening against the Consolidated Canadian Autonomous Sanctions List if, for example, their corporate compliance policies or contractual obligations require them to do so.

Do you need to license this list if you use third-party content in Compliance Screening?

If you screen your business partners against restricted party list content from third parties (such as Reguvis or Dow Jones) in your AEB Compliance Screening application, the Consolidated Canadian Autonomous Sanctions List may already be included in your content. In that case you do not need to license this list separately/additionally. For more information, please contact your content provider.

Efficient restricted party list screening – the Consolidated Canadian Autonomous Sanctions List and more: How can AEB help?

The AEB Compliance Screening Module takes care of restricted party list screening against the Consolidated Canadian Autonomous Sanctions List and performs the screening automatically in the background – upon request also integrated into SAP®, Salesforce, Microsoft Dynamics 365, and other ERP and CRM systems. Please find anoverview of AEB's available restricted party lists here.

• If you wish to include the Consolidated Canadian Autonomous Sanctions List in your Compliance Screening, please request a non-binding quotation. Via the form, you can also contact a product expert.