On March 10, 2016, Canada quietly amended the Regulations Amending the Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations and repealed provisions concerning Egypt. Schedule 2 designating “politically exposed persons” in Egypt has been repealed. This means that the provisions of the Freezing of Assets of Corrupt Foreign Officials Act no longer apply to any Egyptian official.
This means that Canada does not have any restrictions on doing business with Egypt or Egyptian officials other than the usual export controls and trade restrictions applicable to most other countries/officials. Canadian businesses may engage in business with and deal with property of persons who were formerly designated as “politically exposed persons” on the Egyptian list. Further, reporting obligations end and Canadian businesses no longer must report property in one’s possession of Egyptian “politically exposed persons.” This means that the ongoing reporting obligation on financial institutions also ends.
The Freezing Assets of Corrupt Foreign Officials Act authorizes the Governor-in-Council (that is, Canadian Cabinet) to make orders directing that the property (whether real or personal), situated in Canada, of a “politically exposed foreign person” be seized, frozen or sequestered. The Freezing Assets of Corrupt Foreign Officials Act also authorizes the Governor-in-Council to make orders restricting the dealings that any person in Canada or any Canadian anywhere in the world may have with such a “politically exposed foreign person.”