Canada’s economic sanctions regime | S3 EP3

Sanctions compliance is increasingly complex: events in the past 12 months have triggered rapid developments in sanctions regimes in Canada and across the globe. When there is little guidance from Global Affairs Canada (GAC), how can businesses navigate the patchwork of statutes and regulations? What should Canadians do if a counterparty becomes the subject of economic sanctions? And how can you reduce your sanctions risk profile?

In this episode, we are joined by Stephen Nattrass and welcome back Alison FitzGerald who share their insights on what all these changes mean for Canadians. Stephen is a partner in our Ottawa office and head of the regulations and investigations team in Canada. Stephen’s practice focuses on a variety of international trade, regulatory and economic sanctions matters. Alison is a partner in our Ottawa office whose practice focuses on international trade, investment and international arbitration. 

CPD credits: This episode is accredited for 0.5 Substantive hours in Ontario and 0.5 Substantive hours in British Columbia. 

Transcript

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Transcript:

Alison FitzGerald  00:00
Large multinationals are in a difficult situation right now, I think there is going to be a big shift in approach to compliance. Sanctions in most parts of the world is not simply a cost of doing business issue, criminal liability often does attach, it's not enough to take at face value, what's presented to you on-- on paper. Companies really do need to push beyond kind of a first glance and approval when they're entering a new jurisdiction, when they're getting into business with a new partner.

Ailsa Robertson  00:33
Hi, you're listening to Disputed, a Norton Rose Fulbright podcast, and in this episode, we want to provide businesses with an overview and update on Canada's economic sanctions regime. Sanctions compliance continues to become rapidly complex. The past 12 months in particular have seen significant developments in sanctions regimes, not just in Canada, but across the world in response of course, to the war in Ukraine, as well as other conflicts and human rights abuses taking place across the globe. In this conversation, we hear about how Canada's sanctions are implemented under a patchwork of statutes and regulations, and how depending on the nature and location of your activity, it is very possible that certain conduct could also be engaging sanctions laws of another jurisdiction. Compounding the complexity for companies is the limited guidance that we've received to date from Global Affairs Canada, which is the body that administers Canada’s sanctions regime. We hope this discussion will help businesses and compliance teams in particular, in their understanding of how to navigate the current sanctions framework, including steps to take to reduce the risk of violating sanctions laws, and what to do if businesses find themselves in a transaction or relationship that may be the subject of an economic sanction. To talk us through these issues, we welcome back Alison FitzGerald, a partner in our Ottawa office whose practice focuses on international trade, investment and arbitration. Alison regularly advises clients on economic sanctions, export controls, and business ethics across a number of industry sectors including oil and gas, construction, natural resources, and defense procurement. Joining Alison, is Stephen Nattrass, head of the regulations and investigations team in Canada, and also based in Ottawa. Stephen focuses on a variety of international trade, regulatory and economic sanctions matters, and has advised on internal investigations across multiple jurisdictions with a practice that also covers competition, privacy and anti-spam law. If you have any questions about the content covered in this episode, or would like to contact our guest speakers, please reach out at disputed@nortonrosefulbright.com. 

Okay, Stephen, Alison, welcome to the podcast and thank you very much for joining us. So this episode is about Canadian economic sanctions. What do we mean when we talk about economic sanctions?

Stephen Nattrass  02:46
So I think it-- it may be helpful to start off with, you know, we've heard about sanctions, particularly in the last 12 months, but sanctions itself, or economic sanctions, are not a defined term. Rather, it refers to a set of targeted measures that are aimed to restrict, disrupt or prohibit transactions with a specific target that the government has in mind. In Canada, there's a number of pieces of legislation that enact Canada's economic sanctions regime, there's the Special Economic Measures Act or SEMA. There's the United Nations Act, the Justice for Victims of Corrupt Foreign Public Officials Act, also known as the Magnitsky Act, and then the Freezing Assets of Corrupt Foreign Public Officials Act or the Freezing Assets Act. And each of these pieces of legislation does something a little bit different, and was created for a slightly different purpose. So, the Special Economic Measures Act was created to enact Canada's independent sanctions against its own targets. The United Nations Act follows on from Canada's obligations with the United Nations Security Council, so where the UN Security Council implements sanctions, this is the piece of legislation that Canada uses to follow what the UN Security Council is doing. The Magnitsky Act is-- is really used to target specific individuals who are believed to be involved in kind of human rights abuses or corrupt-- corrupt acts. And then the Freezing Assets Act is used at the request of a foreign country to block assets of certain individuals who have been involved in corrupt acts in their home country, that Canada implements at the request of foreign countries.

Alison FitzGerald  04:32
So maybe I'll-- I'll jump in, just to expand on some of the points that Stephen made. Typically, when Canada implements sanctions, it does so in coordination with allied states. So obviously, when it is implementing sanctions under the UN Act, it's doing so pursuant to a UN resolution. All UN member states are expected to follow suit. When it implements sanctions under its own autonomous regime, that still typically it's working with allied states. And so what you will often see is, it's moving generally in concert with our neighbour to the south, the United States, with the European Union, with the UK. You'll see a resonance of our sanctions against particular countries or terrorist groups in all of these other jurisdictions. In terms of the foreign policy behind the use of these tools, the impetus behind sanctions is normally to bring about change, to bring about regime change, to bring about policy change, generally speaking, to bring about a change in conduct that Canada has determined is sanctionable. On the basis of one of the provisions, for example, in our autonomous sanctions regime, Special Economic Measures Act or under the Magnitsky Act. As Stephen mentioned, where there is an observed or believed abuse of power by a foreign government regime, or where there is an act of aggression at the Canadian government may determine that it is going to respond by means of imposing sanctions in order to shape the outcome of that exercise of aggression, or imposition of regime or human rights abuse. Of course, while Canada normally seeks to work in concert with allied states, sanctions do not always align perfectly. And the non-alignment of sanctions regimes cannot only reduce the effectiveness of sanctions for their intended purpose, but can also cause serious challenges for supply chains.

Andrew McCoomb  06:43
So I mean, maybe that's a useful jumping off point to talk about the example the-- the elephant in the room, I mean, can you ground that kind of foreign policy structure for the listener in terms of the international response to Russia's invasion of Ukraine last year?

Alison FitzGerald  07:01
Canada has implemented sanctions against Russia as a result of the aggression in Ukraine. They've done so under our autonomous regime. There are no UN sanctions in place currently against Russia. But we have been building out progressively sanctions against Russia during the course of the past year and continuing into this year, in response to the steps taken by the Russian government in Ukraine. The Canadian government has also implemented sanctions in respect of certain of the breakaway regions in Ukraine, where they are de facto under Russian control. And, as I mentioned before, when acting under our autonomous regime, Canada is normally is working with its allies, and there is right now a strong alliance of Western states that have taken a firm position with respect to Russia's aggression in Ukraine. And there's a high level of coordination both in the sanctions packages that have been rolled out, as well as enforcement efforts across jurisdictions with respect to those sanctions.

Andrew McCoomb  08:09
Yeah, and obviously, that-- that uniformity and consistency and response across sanctions is essential to their efficacy, they can have the effect of, you know, suffocating nation or a group of individuals in a nation who, you know, are the expected or intended target of whatever that-- that action supposed to be.

Stephen Nattrass 08:34
I think that's-- that's right. And, you know, we'll see this in a number of different areas. One would be, individuals or companies, businesses that are subject to targets or freezing asset restrictions. It's not the same list between Canada, US, UK and EU. But by and large, it's a lot of the same individuals, the same companies who are targeted by all of these sanctions regimes, doesn't mean that they all come into force on the same day or the same week, but they are by and large, the same. Another area of-- of sanctions is restricted goods or technologies. So you may see, for example, restrictions on export of luxury goods from Canada to certain jurisdictions, and those lists of luxury goods, for example, craft beer out of Canada, you may see that on other countries lists as well. Same thing where you will often target an industry within a country. So, oil and gas is often one that is targeted, because it generates a lot of wealth for foreign countries. So you'll often see similar packages of sanctions enforced throughout different jurisdictions. 

Ailsa Robertson 09:44
Who has to comply with these sanctions laws?

Alison FitzGerald  09:47
Well, in Canada, generally speaking, all of our sanctions will apply to persons in Canada, whether you're Canadian or not, whether you are an individual or a corporation or a charity. They also apply to Canadians, wherever they are in the world. So this can be important, for example, if you have a Canadian on a board of directors for a foregin incorporation, wherever that foreign corporation is incorporated, it may or may not be subject to sanctions in that local jurisdiction, but our sanctions will follow the Canadian wherever they go. Canadian entities investing abroad will also again need to carefully consider the entities that their partner-- partnering with, individuals that that they're partnering with, et cetera. Our sanctions work a little differently, tend to work a little differently than some other jurisdictions like the US, which is well known to legislate extraterritorially in this space. So for example, a contract that is denominated in US dollars will still attract the application of US sanctions laws. Our laws in the space don't stretch quite that far.

Stephen Nattrass  11:07
With respect to US jurisdiction, you know, a company that is listed on a US stock exchange, they'll also be subject to economic sanctions regime, I think, and a practical point for Canadians to remember is, there's a lot of dual citizens who may be living and working in Canada. But if you are a dual citizen, you're working in Canada for Canadian company, you also need to be aware of the application of US sanctions to you.

Andrew McCoomb 11:32
For the domestic party who wants to, or chooses to deal with those sanctioned individuals, you know, notwithstanding the sanction, what are the consequences for them of crossing that line?

Alison FitzGerald  11:46
The consequences for a Canadian or a person in Canada under our regime are severe. This is not a cost of doing business type penalty. Conversely, because this is penal legislation then for the Crown to move forward with the prosecution, for example, they would need to prove both an actus reus and a mens rea. So there needs to be a willful intent to violate one of the sanctions prohibitions, there needs to be proof of that, or at the very least, willful blindness. But the penalties can be quite severe, and they can range from very steep fines for individuals and corporations, to terms of imprisonment for individuals up to a maximum of five years, if the Crown were to proceed by way of indictment.

Ailsa Robertson  12:33
Presumably, if the corporation is subject to those proceedings, there's personal criminal liability risk for directors and officers too. Given the reality of multinational businesses and international M&A activity, it  may not always be clear cut who you're dealing with, and what their involvement is, and where they’re even located. So, what options are available for a business that is contemplating commercial activity, in or with a country that may be subject to economic sanctions?

Stephen Nattrass  13:05
The first thing to keep in mind is to really, is to do due diligence as early as possible, both in terms of, you know, the country that you're looking at doing business with. So what are the what are the current economic sanctions that are being imposed against that country? You may want to look at other jurisdictions and see what they're doing. You know, there may be additional economic sanctions that follow, which may, you know, the business that you're doing today may be okay, but you know, five, six months down the road, the company that you're doing business with may be then subject to economic sanctions, and then what are you going to do how you wind down that business? You'll be wanting to look at the business partner that you're potentially going to be doing business with, doing due diligence on them, the ultimate beneficial owner, so you're going to want to look up the chain of companies and see who ultimately controls the company, you want to look at management to the board of directors see if there's any sanctioned individuals who are on those, who are kind of controlling the entity.

Alison FitzGerald  14:03
You need to be actively asking questions. Every Canadian and Canadian business that is looking to do business abroad right now needs to be asking questions about their counterparts, they need to be finding out who it is that they're doing business with, and if red flags do appear, they need to actually dig in and explore. It needs to be, I think, a conversation that Canadian companies are taking up as a part of-- as a part of their general compliance, when entering into a transaction, whether it's purchase and sale transaction, whether it's a joint venture, whatever it is, they need to have in mind that their antennae are up. They're asking questions, they're having the conversations, and then they're documenting their file.

Stephen Nattrass  14:56
The documentation is important. It's asking questions, asking follow-up questions, getting copies of documentation, verifying the documentation. You know, and where there is resistance to having these open discussions, do you actually be wanting to do business with this entity?

Andrew McCoomb 15:12
It's really interesting that diligence leads, I think, to the logical question of what you believe you can do with it. If you find yourself in a circumstance where, say, a longstanding business partner finds themselves subject to sanction and that business partner, and their you know, their supply revenue is critical to what you do in Canada. I mean, what are your options if you--, you have a change of circumstance or someone you've been working with faces sanctions, and you've done your diligence, and it's a relationship that you want to persist with? Are there exceptions? Are there ways to work around sanctions? How can you be strategic in sort of going about maintaining that relationship in the face of something like this? 

Alison FitzGerald  15:53
Well, I think that's the starting point is to ask yourself, is this a relationship that you can and should maintain, right? Or is this a relationship that is no longer one that-- that you should be maintaining. You review the contracts that are in place, you review whether or not there's a contractual release through a force majeure clause, or a compliance with laws clause, to assess your own potential liability, if you need to get out of the contract, or you're no longer able to comply. There are tools within the sanctions legislation as well. Just speaking to the Special Economic Measures Act, there are some exceptions that are often baked into regulations, it's quite common to see exceptions that would allow Canadians, for example, to continue to receive a payment that is owed to the company under a contract that had been entered into, prior to a person being designated as a designated person. So that-- that's one instance where that could continue. Occasionally, the government will build wind-down clauses into the regulations, it's less common to see in Canada than it is in the United States. But, you do see this in some instances where, for example, again, in respect of a contract that was in place, and entered into with a foreign person prior to the point in time, when that person is sanctioned, you may have a grace period of say, six months, to continue to perform under that contract, understanding that it will need to be wound-down by the end of that period, unless you obtain a permit. And that's the further step that you could take if an assessment is made that continuing to engage in activity under that contract, would violate sanctions legislation, then you can turn to Global Affairs Canada, and put in an application for a permit to continue the activity in some capacity. And then that's something that would ultimately have to be decided by the Minister of Foreign Affairs.

Stephen Nattrass  18:07
And I think it's, you know, in respect of putting in a permit application, it is ultimately the Minister of Foreign Affairs who makes a decision. But it's a completely discretionary decision. And it's a decision for which there is no either legislative-- legislative timeline to make that decision. So these decisions are not, one) they're not automatic and two) they're not immediate. You may end up waiting, you know, three months, six months, a year. There's a significant backlog before Global Affairs Canada at the moment, who will do the initial review and screen of a permit application, and ultimately make a recommendation to the Minister of Foreign Affairs, to issue or to deny a permit. So while that is an option, it's absolutely not guaranteed. And that shouldn't be viewed as a way of doing business with, you know, a sanctioned party.

Ailsa Robertson  18:57
One of the interesting developments to monitor alongside the proliferation of various laws that we're seeing, that we’ve talked about, is the enforcement strategies when it comes to potential sanctions violations. Can you talk a bit about new enforcement trends that you're seeing. What tactics are being employed? For example, are we seeing more dawn raids, more investigations? And is there an increasing approach to perhaps self-disclosure, and the RCMP working with companies in that respect when it comes to potential sanction violations?

Stephen Nattrass  19:30
As Alison mentioned earlier, economic sanctions are criminal. It is enforced through criminal means. So it is the federal RCMP who will do the investigations, and ultimately make recommendations to the prosecutor under the federal prosecution service as to whether or not to lay charges and follow through with a criminal case. That being said in Canada, traditionally, there has not been significant enforcement activity. But I think we are going to be seeing as a trend going forward, a lot more enforcement activity. The federal government in the last 12 months announced an additional $76 million investment, which will be to the Global Affairs Canada sanctions team to increase staffing, as well as funding for the RCMP to enforce sanctions more robustly. And we think that this is going to help to see additional enforcement activity going forward as these kind of staffing increases at both Global Affairs and RCMP in relation to enforcement.

Alison FitzGerald  20:37
In addition to the fresh funding that Stephen mentioned a moment ago, to help support enforcement as well as the triaging of permit applications and requests for guidance into Global Affairs, the government did amend the Special Economic Measures Act and the Magnitsky Act last year, in order to introduce a new power for the government to essentially seize and forfeit and then repurpose assets that are believed to, belong to, or be controlled by a designated person. The Canadian government has already taken some initial steps in this direction using that new tool in the Special Economic Measures Act, in order to seek the seizure and forfeiture of assets that are believed to have been owned or controlled by Roman Abramovich, who is a high profile Russian oligarch, and has been listed in Schedule 1 of the Special Economic Measures (Russia) Regulations. One of the challenges, I think, in the operation of that new tool or the use of the new tool is that, assets can still fairly easily be shifted, ownership can be transferred, it can be a little bit of a shell game in terms of drilling down to find out who is still owning an asset, and whether or not you can trace through for purposes of seizing and-- and having it forfeited to the Crown. But the goal of that tool really was to ensure that the Canadian government could take steps to seize and have funds forfeited in order to repurpose them to things like rebuilding a state that has been the subject of the aggression, that the-- a set of sanctions regulations are targeted to, to influence in-- in foreign policy terms.

Ailsa Robertson  22:38
What guidance is there available for companies trying to navigate this proliferation of economic sanctions at the moment?

Stephen Nattrass  22:47
Nothing, there's no Canadian guidance that has been issued, which is somewhat frustrating for Canadian businesses who do want to comply with Canada's economic sanctions regime. They want to do the right thing. We have heard some discussion that there may be some forthcoming guidance that there is a draft, but there is nothing that has been released to date. This is in sharp contrast to Canada's allies, particularly the US where there's significant FAQs from OFAC, you can go to OFAC, you can ask them for kind of ‘no names’ opinions or how they would view US sanctions legislation, how would be interpreted on specific facts. It's also very different from the UK and EU where there's also significant economic sanctions guidance. What did get issued by Global Affairs Canada was on April 1st 2022, they took the unusual step of publishing an advisory to Canadian businesses on Canada's sanctions related to the Russian invasion on Ukraine. And it doesn't actually provide guidance on how to interpret the regulations or its sanctions but rather indicates a Canadian businesses should, or must comply with Canada's economic measures, and that Canada will enforce its sanctions regime. 

Ailsa Robertson  24:07
Why is there such opacity given the severity of the consequences for non-compliance? Why is there such opaqueness by GAC? Is it a resourcing issue, or is there is there anything else at play here, and how does that lack of guidance play into perhaps your defense strategy?

Alison FitzGerald  24:27
Well, just to jump in on one point, we do now have a tool, a searchable tool, that is fairly comparable to the searchable tool maintained by OFAC. There is a place on Global Affairs site where you can search the names of individuals companies, across all of the regulations that have been enacted under the Special Economic Measures Act as well as the Magnitsky Act, in order to determine whether or not the individual or-- or company in question is subject to sanctions somewhere. So that is an improvement. That tool does come with a disclaimer though, which is that it's not an official statement on whether or not you know, an individual or-- or company that you populate and search across that database is, in fact, a sanctioned person. And occasionally spelling errors, for example, are made. And so you might not, in fact, pick up through that search tool, a person who's been sanctioned. The best-- the best approach is still to go back to the regulations themselves, which will list within the body of the regulations in a schedule, all of the persons that have been designated for purposes of-- of those sanctions, in terms of why GAC hasn't moved to publish broader guidance on any of the sanctions legislation or the key terms that you see used throughout the regulations, I honestly don't know. It's been an issue for some time, there was a parliamentary committee that looked into sanctions back in 2017 and a recommendation made that guidance should be published at that time, we still haven't seen it. As Stephen mentioned, it is a challenge. It is a challenge for companies that are looking to comply and looking to understand our sanctions. It's also a significant challenge for individuals, even retirees who have their funds, for example, in international banks, who are inadvertently caught by our sanctions, because funds are transiting through a correspondent bank that happens to be sanctioned, for example. All of these individuals and corporations now, are either turning to people like Stephen and I, for advice to understand how to interpret and comply with our sanctions or they're turning directly to Global Affairs. And that is, what is compounding the resourcing issues with Global Affairs right now.

Stephen Nattrass  27:10
And I think an important point to flag on the lists is that while there are searchable lists online, they're not entirely perfect. And that's not, and that shouldn't be the start and the end of your due diligence, when we're talking about due diligence and what's required. It is a helpful tool, but you also have to look at other factors, and you know, you may be a subsidiary of an entity who's been sanctioned in the US, there's also what they call the 50% Rule. So you have to look not just at the entity that is on that OFAC list, but also entities that are 50% or more owned by those entities. So you have to look down the chain or up the chain, it's not just are you listed or are you not listed. That actually kind of brings up an interesting point, unlike a Bill which goes through Parliament, and you have an idea that this piece of legislation is coming and you may have to take steps to become compliant with legislation. Economic sanctions regulations, are simply announced by-- by Global Affairs Canada, they're posted on the website, they then go into the Canada Gazette, they come into-- into force as soon as they are enacted and announced. So there is-- they are quick moving, they do change rapidly, or they can change rapidly. And in a few instances, Global Affairs Canada has actually retroactively imposed sanctions. So they came into force a day or two before they were actually publicly announced, which could actually put you into a position of non-compliance or breach of economic sanctions legislation.

Alison FitzGerald  28:42
It's one of the issues that has compounded some of the challenges with respect to compliance because you have to actively be on the alert. If you do have, for example, investments in a jurisdiction that's subject to sanctions. As Stephen mentioned, sometimes, a new slate of designated persons will be posted on Global Affairs site, and that list will take effect as of for example, midnight, the list could go up just minutes to midnight. By the same token, some of the sanctions that are being put into place, are much broader--, broad categories of goods that may be prohibited for export or import again. Many of these prohibitions will take effect as soon as they are posted. There is some greater effort, I think I can see being made, to include wind-down clauses, which again aligns the approach a little bit more closely to what the US will commonly do. The US will often, when they publish new sanctions, will give regulatees a period of time to adjust and ensure there's for example, an orderly wind-down of a transaction or the orderly wind-down of a business. I think we're seeing some movement in that direction in Canada, but it's--, it's not a guarantee. In some cases, you will be potentially offside immediately, and then you'll need to determine what steps to take. You might need a permit in those circumstances in order to carry out the wind-down of a transaction, or of a business. In circumstances where you can demonstrate that the grant of a permit is aligned with Canada's foreign policy goals, in connection with the sanctions in question, you will normally stand in better stead and securing that permit.

Andrew McCoomb  30:35
And say then, that company is doing its diligence and it realizes that in fact, maybe has engaged in business with someone who's subject to sanctions, in violation of those sanctions, what are they to do at that point in time? Do they wave the white flag and report themselves? Do they try to deal with it internally? I mean, what's the best approach for that kind of situation when you’ve discovered that it's happened.

Stephen Nattrass  30:58
I think one of the first things to do is to look at exactly what had happened to determine the facts. Who was involved? Was it an accidental, you know, a mistake? Was it someone acting on purpose? As you said, it's not one size fits all. So you're gonna have to look very much at the facts. What happened, jurisdictions involved, is it only Canada? Is it other sanctions regimes that have been implicated? Broadly, in the last couple of years, the RCMP has been encouraging more self-disclosure generally. There is a unit within the RCMP that will deal with and investigate economic sanctions issues. They're willing to have those discussions, and to have those disclosures. Doesn't mean that they will automatically recommend prosecution, but they are definitely open to having those discussions and-- and to hearing from Canadian businesses who may be in breach. Of course, it is criminal legislation so there is no obligation to report the commission of a crime in Canada, but it is becoming more and more recommended to self-disclose. 

Andrew McCoomb 32:07
And we just did a fascinating episode on re-- remediation agreements with some of our colleagues from Montréal who were involved in the first remediation agreement in Canada, since that legislation was introduced. But I take it, that remediation agreement approach wouldn't be available if international sanctions violations are among the categories of conduct or misconduct, for which a remediation agreement would be an appropriate response. So that's--, that's not a path out here, when at least as far as the status quo is concerned, if you have discovered a breach? 

Stephen Nattrass  32:46
That's correct, so economic sanctions offenses are not included within the remit of what will be available for remediation agreement. But that may ultimately go to, you know, if the conduct is so offensive that the RCMP recommends that charges be laid, you know, and then the company decides to plead guilty, for example, that may be a mitigating factor. The fact that you actually did self-disclose that to the RCMP as opposed to not self-disclosing it and waiting for that to come to the regulator's attention, which then may require more investigation and government resources, which would ultimately impact the penalty or the fine that they agreed to or imposed.
Andrew McCoomb 33:25
Alison, Stephen. So often, we end these episodes by reflecting on how what we've just heard about, how it, you know, sounds like it's in a state of flux. So if you'll indulge us we’ll—we’ll very gladly invite you back if you’ll make time for us. So thank you very much for sharing your insights. 

Alison FitzGerald  33:44
Thank you. 

Stephen Nattrass  33:45
Thank you.

Ailsa Robertson  33:45
We hope you enjoyed this episode of Disputed. If you'd like to find out more about this topic, or how to contact our guests, please visit nortonrosefulbright.com/disputed. Also, if you have any questions, feedback, or topics that you'd like us to cover in a future episode, please do email us at disputed@nortonrosefulbright.com. And if you would like to hear more, please subscribe to Disputed on Apple Podcasts, Spotify or wherever you get your podcasts. 

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