Most Canadian export controls and controlled goods compliance programs are built with the assumption that relevant employees who have access to controlled goods and technical data will be working in an on-site work environment and use work computers and in-house servers where information is securely stored with access and release restrictions and where work-related activities

On April 16, 2020, the Government of Canada issued Notice to Exporters Serial 992 “Notice to Exporters – Export of items listed on the Export Control List to Turkey” in which Canada announced that it will presumptively deny any new export permit application with respect to military goods on the Export Control List where the

During the COVID-19 global pandemic, an important humanitarian issue has arisen for individuals (friends and family), companies, and non-governmental organizations.  Many Canadians and residents in Canada have asked whether they can export humanitarian goods (including personal protective equipment (“PPE”)) to countries against whom Canada has imposed sanctions (called “Sanctioned Countries”). Canada clearly exempts humanitarian activities.

On April 1, 2020, the Government of Canada published in the Canada Gazette “An Order Amending the Export Control List”, SOR/2020-48 (P.C. 2020-140).  This Order takes effect on May 1, 2020. The objective of this Order is to implement the Government of Canada’s arrangements, commitments and policies resulting from Canada’s participation, up until

On October 15, 2019, Global Affairs Canada informed reporters that new export permits of military equipment and technology and brokering permits in respect of goods destined for Turkey would not be approved.  There was not a formal Notice of Exporters (possibly because Canada’s federal election campaign was underway – election was held on October 21st).

It has been a busy year in Canada for export controls and economic sanctions developments. As a result, we are posting an H1 2019 report. The top 10 developments in H1 2019 are:

1. Canada will implement the brokering rules on September 1, 2019. Bill C-47 “An Act to amend the Export and Import Permits

In March, there was a good deal of consternation in the general press trying to understand news that President Trump had overruled the actions of the Office of Foreign Assets Control (“OFAC”) to impose additional sanctions on North Korea. Beside the oddity of a President overruling actions by a part of the Executive branch after

Canada

This is a common problem – too common.  The people in the company responsible for customs and trade compliance do not work closely with the computer programmers as software is being developed — and mistakes are made.  The computer programmer does his or her job in preparing the code, but does not have any

Canada

Countries, such as North Korea, Iran and Russia, may attempt to hide activities by using cryptocurrencies (such as Bitcoin). While the underlying activity of selling controlled goods or dealing with designated persons is illegal (under Canadian export laws) without an export permit/ministerial authorization, a secondary issue is enforcement.  Enforcement tools directed at “following the

Canada

Canada’s export controls go beyond dual-use goods, chemicals, defence and military items, and other goods on the Export Control List.  Canada imposes export controls under a variety of statutes and regulations.  For example, Canada controls exports of cannabis, cultural property, hazardous waste, hazardous recyclable and scrap materials, rough diamond, human pathogens, honey, maple syrup,