In brief
The Government of Canada has established additional avenues to administer and enforce Canadian sanctions laws. Specifically, the government is relying on the existing legislative framework under the Proceeds of Crime, Money Laundering, and Terrorist Financing Act (PCMLTFA) and its administrative agency, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) alongside the Canada Border Services Agency (CBSA) to establish a sanctions civil enforcement regime in the form of mandatory reporting on suspected sanctions evasion for prescribed entities, importers, exporters and those financing import/export transactions. The government has also amended the Criminal Code, lessening the prosecution’s evidentiary burden when prosecuting money laundering charges (which may be tied to sanctions evasion). Finally, the government has proposed amendments to expand the PCMLTFA’s terrorist property reporting regime to include reporting on property owned, held or controlled by designated persons.
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