Canada Published New Sanctions Ownership Guidance

The government issued new criteria to help entities determine control under sanctions legislation.

Updated on Oct. 14, 2026 in International Trade

Canada Published New Sanctions Ownership Guidance

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Should governments impose strict ownership thresholds to prevent entities from bypassing international sanctions?

Canada has released updated guidance concerning deemed ownership thresholds as part of its sanctions enforcement framework. The information assists organizations in identifying when an entity is under the control of those restricted by the Special Economic Measures Act.

Why it matters

The guidance is designed to help entities avoid breaching sanctions indirectly by clarifying how control is assessed. It ensures that businesses can effectively navigate prohibitions against dealing with property controlled by sanctioned parties.

An entity is officially considered controlled if a sanctioned person holds 50% or more of shares or voting rights, or has the power to direct board composition. These thresholds apply when assessing interests in the aggregate.

The players

Global Affairs Canada

This federal department manages Canada's diplomatic relations, international trade, and the administration of the country's sanctions regime.

The details

The guidance outlines three distinct criteria for determining control, including the ability to influence an entity’s board or direct its activities in practice. Entities are now directed to consult the Global Affairs Canada sanctions website to align their compliance programs with these standards.

June 2023: Deemed ownership provisions were added to the sanctions legislation.
October 14, 2026: Canada published the new guidance on deemed ownership.

Market Dynamics

This guidance clarifies the operational interpretation of the Special Economic Measures Act in response to complex corporate ownership structures. It reflects a broader shift toward tighter scrutiny of indirect asset control within international trade and financial regulation.

Businesses and financial institutions must update their internal screening procedures to ensure compliance with the 50% aggregate ownership rule. Failure to align with these clarified criteria could result in accidental violations of existing sanctions legislation.

The takeaway

Organizations should review their current ownership structures to ensure they do not inadvertently hit the 50% aggregate threshold for sanctioned entities. Proactive alignment with the latest Global Affairs Canada criteria is essential for maintaining regulatory compliance.