Global Economic Sanctions

As of Aug. 19, 2024, FINTRAC’s amended regulations to the PCMLTFA via Bill C-59 create a new requirement for reporting entities to report sanctions evasion for the very first time. Bill C-59, “the Fall Economic Statement Implementation Act, 2023,” requires entities subject to the PCMLTFA to report suspected sanctions evasion transactions to FINTRAC. In effect, reporting entities could be subject to FINTRAC’s administrative monetary penalties for failing to report transactions that might violate Canada’s sanctions laws.

During this panel, we will explore:

• Interpreting the latest key amendments to the PCMLTFA
• How to prepare for stricter due diligence obligations related to sanctions evasion measures and the impact on businesses
• Understanding the characteristics of attempted or completed financial transactions that could amount to suspected sanctions evasion
• Best practices for implementing controls and measures to mitigate risks
• Reviewing and updating your sanctions and AML policies to integrate new reporting requirements

As governments around the globe impose new sanctions at a rapid pace, organizations must be ready with ramped up efforts to mitigate the risk of violations and penalties. During this panel, we will delve into the challenges of complying with overlapping sanctions regimes across Canada, the U.S., the UK, and the EU. Join this panel discussion as we explore:

• Strategies for managing the intricacies of conflicting legal standards, enforcement priorities, and reporting obligations
• Practical solutions for ensuring compliance and maintaining operational efficiency amid rapidly changing sanctions landscapes
• Comparing and contrasting EU, UK, and U.S. sanctions—recent developments and enforcement trends
• Best practices for building your multi-jurisdictional sanctions compliance program

Join us for a special keynote focused on the FATF assessment and its 5-yearreview, where Department of Finance Canada will give insights into the assessment of sanctions risk exposure in Canada. What does the FATF assessment mean for stakeholders? Learn about new legislation, heightened expectations and guidance.

As companies and financial institutions prepare for the expansion of sanctions and export control restrictions with respect to China, there is an urgency for enhanced due diligence and real-time monitoring of supply chains, particularly in industries with heavy reliance on Chinese technology or manufacturing. During this panel, we will explore:

• Scenarios: Working through challenges and consequences of expanded China sanctions and export controls by the U.S., Canada and more jurisdictions
• The current landscape of automated solutions for screening transactions and specific flagging violations of humanitarian law
• Adapting your teams to real-time changes in legal frameworks
• Xinjiang, human rights-related designations, and the interplay with UFLPA

During this panel, we will explore the uptick in delistings and updates, and how organizations are facing heightened challenges, including:

• A closer look at the latest Delisting Guidance
• How minority shareholders are dealing with their assets
• How are minority shareholders acting with non-sanctioned parties, and what kinds of issues should be examined?
• A look at the delisting application process

Join us for an important discussion on asset seizure and forfeiture through both a Canadian and U.S. lens. During this panel discussion, we will unpack the latest amendments and more, including:

• Clarifying the process for seeking forfeiture under Canada’s Special Economic Measures Act (SEMA)
• Developing stronger due diligence protocols amid increasingly sophisticated money laundering and other financial schemes
• Practical implications for organizations to consider
• How proceeds of asset seizure and forfeiture are being used for the reconstruction of Ukraine

The next phase of Russia sanctions compliance is marked by increasingly sophisticated and targeted measures with a mounting overlap between sanctions and export controls. Recent developments, which have expanded restrictions on sectors like energy, defense, and critical technologies, have tightened the scope of permissible business with Russian entities. During this panel, we will explore:

• An overview of recent developments and lessons learned related to the correlation between sanctions and export controls
• Anticipating measures that might restrict access to advanced technologies and dual-use goods
• Ensuring supply chain transparency and compliance with both U.S. and international export control laws
• Russia sanctions and export controls through a U.S. lens
• The latest in sanctions evasion and how Russia is setting up new branches for subsidiary banks
• Navigating the complexities of key language in legislation and Russia sanctions regimes

Join this panel as we explore the expansion of sanctions on Iran across multiple jurisdictions, including:

• Latest U.S., UK, and EU sanctions against Iran
• The impacts and latest in Iran’s ghost fleet and illicit shipping actors
• Sanctions implications and 2024 year-end updates to sanctions against Iran, including OFAC’s economic sanctions enforcement guidelines
• Exploring the Iranian-Russian-Chinese alliances
  • The Russia-Iran military cooperation
  • How Iran is helping Russia evade sanctions

In June 2023, as part of the Budget Implementation Act 2023, there were significant amendments made to Canada’s sanctions statutes—the Special Economic Measures Act (SEMA), and the Justice for Victims of Corrupt Foreign Officials (JVCFOA). As a result of these amendments, ownership and control rules were clarified, expanding the scope of due diligence on counterparties that might be owned or controlled by sanctioned parties. During this panel discussion, we will explore:

• Enhancing current due diligence standards to satisfy key requirements
• Big compliance missteps to avoid—best practices and lessons learned
• How to address the complexities of compliance with the new amendments—a look at the real-world challenges and how to manage them

Strengthening your third-party risk assessments in regions like Russia, China, and other key hotspots requires a strategy that includes evaluating geopolitical factors, regulatory compliance, and the financial stability of potential partners. Key topics during this session include:

• Conducting enhanced due diligence that encompasses not only financial and operational capabilities, but also an understanding of potential exposure to sanctions risks and international political unrest
• Regularly updating risk assessments and establishing clear communication channels with partners
• Mitigating the impacts associated with supply chain disruptions
• Leveraging real-time, third-party risk monitoring solutions that considers a multi-jurisdictional approach
• Approaching due diligence “up” the supply chain and industries implicated by supply chain restrictions

Instant payment systems are creating both high reward and high risk for Canada’s payments infrastructure. During this session, take a dive into the Real-Time Rail (RTR) and learn the latest sanctions compliance guidance in the world of instant payments. Discussion points include:

• Understanding the latest with the Real-Time Rail system and the real-life implications for financial institutions
• How RTR is changing the payments sphere in Canada
• Exploring the world of real-time payments and the aligned need for real-time compliance
• How industry will prepare for misuse of the payments rail
• The impact of RTR expanding to include non-banking MSBs in sanctions
• Current guidance on Real-Time Rail

Join our closing panel as we explore the evolving impact of U.S. sanctions on Cuba in the Canadian context, with discussion points including:

• Managing overlapping sanctions obligations and blocking laws across multiple jurisdictions
• How should companies treat non-sanctioned currencies when financial infrastructures are almost fully sanctioned?
• Best practices for navigating conflicts between sanctions regimes, and how to efficiently deal with blocking orders