Global Economic Sanctions

This panel brings together Canada’s key regulatory and enforcement agencies to discuss how sanctions enforcement is being approached and coordinated. From audit practices and asset forfeiture to delisting requests and customs screening, panelists will provide frontline insights into enforcement priorities, timelines and regulatory evolution.

Points of discussion will include:

• Reviewing Global Affairs Canada’s guidance on permit delays, sanctions interpretation, and transparency issues
• Clarifying RCMP’s role in STR investigations, criminal enforcement, and CIMA coordination
• Examining CBSA’s enforcement activity and customs red flags involving dual-use or restricted goods
• Exploring inter-agency coordination for asset seizures, investigations, and prosecution efforts
• Explaining Canada’s 2023 ‘deemed ownership’ rule and its impact on due diligence and reporting

Conflicting sanctions regimes are one of the most pressing challenges facing multinational businesses. This high-level panel will explore how divergent enforcement, licensing, and other rules and expectations across jurisdictions are reshaping compliance strategies, increasing risk exposure, and complicating cross-border and international operations. Points of discussion will include:

• Assessing ownership / control of designated entities under different regimes
• Evolving U.S. sanctions policy positions regarding Russia, Syria, and the Middle East
• Best practices for handling escalations and matters with multi-jurisdictional impacts

This timely panel explores whether Canada and its allies are staying strategically aligned—or drifting apart—on sanctions targeting high-risk jurisdictions like Syria, China, Iran, and others. As humanitarian carveouts evolve and foreign policy objectives diverge, the consequences for multinational compliance and enforcement are intensifying. This discussion will unpack both the coordination and contradictions among Western allies and their sanctions strategies—and how to calibrate your program accordingly.

Points of discussion will include:

• Comparing Canada’s continued sanctions on Syria with shifting U.S. and EU positions-and the impact on your compliance approach
• Analyzing recent developments in sanctions targeting China, Myanmar, South Sudan, and Iran-and examples of how to update policies, processes and screening
• Understanding how geopolitical priorities influence differences in regional sanctions compliance strategies
• Clarifying where humanitarian carve-outs align and where they create risk for businesses
• Concrete examples of compliance upgrades that incorporate similar and differing sanctions restrictions
• Anticipating the compliance implications of fractured international sanctions frameworks-and revisiting the short, medium and long term of your compliance strategy

AN124 cargo plane at Pearson Airport represents a landmark application of new asset forfeiture powers under the Special Economic Measures Act. This session will explore how Canada and its allies are expanding enforcement through the confiscation of high-value assets—yachts, jets, and more—as part of sanctions regimes targeting designated individuals and entities. Panelists will discuss the legal frameworks in play, cross-border coordination, and what this means for future cases. Points of discussion will include:

• Reviewing how Ottawa seized the Antonov AN124, grounded since 2022 after Russia’s invasion of Ukraine, under newly granted forfeiture laws
• Examining Canada’s intent to ultimately forfeit the plane to the Crown and consider transferring it to Ukraine
• Comparing Canada’s use of amended asset seizure powers with more assertive enforcement trends in the US, UK, and Australia
• How U.S. DOJ and OFAC coordinate asset seizures and criminal cases
• Analyzing how oligarchs attempt to obscure ownership through complex asset structures
• Considering the long-term risks of enforcement delays, contested ownership, and retaliatory narratives

As the EU introduces a dynamic price cap on Russian oil and global enforcement intensifies, Canada must navigate an increasingly complex sanctions and compliance environment in the energy sector. This panel will discuss how price cap regimes, investment risk, and sanctions coordination are shaping decision-making in the Canadian oil and gas landscape. Points of discussion will include:

• Reviewing how Canadian entities, including shippers and insurers, are required to comply with oil price cap enforcement frameworks tied to G7 and EU regimes
• Evaluating the operational impacts of the dynamic price cap model, which the EU will set 15% below global market prices, and its extraterritorial implications for Canadian actors
• Analyzing how sanctions compliance is influencing investment decisions in Canada’s energy sector, particularly for mid-sized producers and global majors operating in Canada
• Hearing first-hand experiences from oil and gas players navigating Russian price cap regimes, and how compliance risk is being assessed internally
• Contrasting Canada’s enforcement posture with more aggressive asset seizure and enforcement efforts in the US, UK, and EU
• Exploring how Canada could align future sanctions policy with allies while protecting domestic economic and energy security interests