Overcoming Hurdles to Complying with Canada’s New Deemed Ownership Rule: Procedures for Satisfying Amendments to SEMA and the Magnitsky Law

March 6, 2024 1:00pm

Umair Azam
Legal Counsel
Canadian Bankers Association

Martha Harrison
Partner
McCarthy Tétrault

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 the amendments, ownership and control rules were clarified, expanding the scope of due diligence investigation that companies are responsible for related to counterparties that might be owned or controlled by sanctioned parties. During this panel discussion, we will explore:

  • Due-diligence challenges related to the new amendments
  • Evaluating current procedures and determining the applicability of the new amendments to different types of businesses
  • Navigating the complexities of compliance with the new amendments—a look at the real-world challenges and how to manage them