Sanctions and export control compliance guide

Objective: Understand the main laws, authorities and official resources that govern sanctions and export controls, and how they differ.

Sanctions

• Canada imposes economic sanctions primarily under the Special Economic Measures Act (SEMA), the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) and the United Nations Act. Country‑ and situation‑specific regulations and lists of designated persons are published and updated on the Canadian sanctions portal.

Export and import controls

• Many goods and technologies are controlled under the Export and Import Permits Act (EIPA), implemented through instruments such as the Export Control List (ECL), Import Control List and Area Control List. Guidance materials, including A Guide to Canada’s Export Control List, and updates are available through the Export and Import Controls portal.​​
• Some goods imported into Canada may also be subject to anti‑dumping and countervailing duties under the Special Import Measures Act. The Canada Border Services Agency (CBSA) maintains a list of measures currently in force. For up‑to‑date information on import tariff changes and administrative updates, consult Canada Customs Notices.

Authorities and roles

• Global Affairs Canada (GAC) administers sanctions policy and export and import controls, including permits and guidance.
• The CBSA enforces many controls at the border and provides an Exporters’ guide to reporting describing exporters’ reporting obligations.

Official entry points

• Canadian sanctions pages explain types of measures, designated persons and key concepts.
• The Export and Import Controls portal centralizes information on controlled products, systems, forms and key updates, including guidance on controlled technology in the cloud and changes to the Export Control List.
• The Canada.ca Export permits and restrictions page links to federal export permit and restriction information for businesses.
• The New Export Import Controls System and New Export Controls Online provide online tools for permit applications, status tracking and compliance management.

Objective: Identify transactions that require additional screening and, in some cases, permits before you quote, sign contracts or ship.​​

Destination and party risk

• Transactions involving countries subject to Canadian sanctions under the Special Economic Measures Act (SEMA) or the United Nations Act.
• Dealings with individuals or entities listed as designated persons on Canadian sanctions lists, including entities they own or control.
• Exports to destinations on the Area Control List, where additional controls and permits may apply.​​

Product or technology risk

•  Goods, software or technology that fall within categories of the Export Control List, such as military items, dual‑use goods, advanced electronics, quantum and semiconductor‑related items, and certain machinery and materials. Updated guidance and list changes are highlighted on the GAC Export Controls portal.​​
• Transfers of controlled technology in non‑traditional forms, such as providing remote access, uploads or cloud storage, which GAC has flagged as potentially controlled movements.​

End‑use and end‑user risk

• Transactions where exported items could support weapons, military or surveillance applications, proliferation-related activities, or other sensitive programs.
• Situations where ownership, control or true end use of the counterparty is unclear or routed through intermediaries.​

Route and financial risk

• Unusual routing, trans‑shipments, payment structures or intermediary chains that may indicate attempts to circumvent sanctions.
• Payment from unrelated third parties, last-minute changes to shipping instructions or destination, or requests to alter documentation may indicate diversion or circumvention risk.

Basic questions before proceeding

Before moving ahead with higher‑risk transactions, answer these basic questions:

• Is the destination country subject to Canadian sanctions, Canada’s Export Control List, or on the Area Control List?
• Are any parties involved, including customers, beneficial owners, banks or intermediaries, identified on Canadian sanctions lists or clearly linked to designated persons?
• Could your goods, software or technology fall within the Export Control List or other controlled lists?
• Could foreign-origin content in your goods or technology create additional export control obligations under foreign re-export rules?
• Will your transaction involve moving or granting access to controlled technology via the cloud or other intangible means?
• Do you need a permit, certificate or other authorization from Global Affairs Canada or another federal authority?
• Have you consulted GAC’s export controls and permits guidance?
• Have you assessed ownership and control structures to determine whether a non-listed entity may still be subject to sanctions due to ownership or control by a designated person?

Objective: Integrate sanctions and export control checks into standard sales, contracting and shipping processes, using official sources as the primary reference.​

For higher‑risk products, destinations or sectors, treat screening as a routine step for each material sales transaction. Do not rely on a one‑time customer onboarding task. This means checking key parties (for example, customer, beneficial owner where known, banks and main intermediaries) against relevant Canadian sanctions lists and, where appropriate, other official lists each time you quote, accept an order or prepare to ship. This is especially important if there are changes in ownership, routing or payment arrangements.

Assign responsibility and governance

• Designate a person or small team to coordinate sanctions and export controls questions, maintain procedures, monitor updates from GAC and liaise with advisers and authorities.​
• In Canada, organizations that examine, possess or transfer items listed on the Controlled Goods List under the Defence Production Act are required to register with the Controlled Goods Program (CGP) and must appoint at least one Designated Official.
• Ensure this role is recognized in your governance so issues can be escalated before deals are signed.

Document a basic screening process

Require screening before accepting orders, signing contracts or shipping for higher‑risk cases, including:​

• Destination and party screening:
  • Check the Canadian sanctions portal and essential information pages to see which measures apply to the destination and to identify sanctions lists for designated persons.
• Product or technology classification:
  • Consult the Export and Import Controls portal and Canada.ca Export permits and restrictions page to determine whether your goods or technology may be on the Export Control List or otherwise controlled, and whether permits are needed.​​
  • For complex items, consider seeking specialized advice on classification and permit requirements.
• End‑use and end‑user due diligence:
  • For higher‑risk items, destinations or sectors, document the intended end use and end user in more detail. This can include collecting a short, signed end‑use statement from the customer that describes how and where the goods, software or technology will be used, and confirms that they will not be re‑exported or diverted in violation of applicable sanctions or export controls.
  • Where practical, update end‑use information when product types, volumes, destinations or ownership structures change, so you are not relying indefinitely on old assumptions about how your products are used.
• Border and reporting alignment:
  • Review the CBSA Exporters’ guide to reporting to ensure declarations and reporting obligations align with your sanctions and export controls assessment and any permit conditions.
• Record keeping:
  • Maintain basic records showing that reasonable checks were completed, such as logs, screenshots from GAC or other official sites, internal checklists and emails documenting decisions, so you can demonstrate good‑faith compliance.
• Escalate and pause when red flags appear:
  • Define simple escalation rules so that certain warning signs, such as potential matches on sanctions lists, unclear ownership structures, unusual routing or payment from unrelated third parties, trigger a pause on quoting or shipping until a designated person reviews the case.
  • Clearly define who has authority to approve, modify or decline higher‑risk transactions, and document decisions and the reasons for them so you can explain your approach to banks, partners or authorities if questions arise.
• Training and updates:
  • Provide short, focused training for sales, logistics, finance and management on basic concepts, red flags, internal procedures and when to escalate.
  • Review Global Affairs Canada portals (sanctions and export and import controls) and relevant Canada Border Services Agency pages at least quarterly for updates affecting your products or markets. Check monthly if your products, markets or sectors are subject to frequent regulatory changes. Adjust internal procedures when updates affect your screening, classification or permit requirements.

• Bookmark and review the official portals on sanctions and export control resources, including the Canadian sanctions pages, the Export and Import Controls portal and Canada.ca Export permits and restrictions, and identify which are most relevant to your goods and markets.​
• Define a simple internal screening routine that specifies who checks what, when and how, using official sources before committing to higher‑risk export transactions.
• Train relevant staff on your routine and common red flags, and keep basic records of checks to demonstrate good faith compliance if questions arise from authorities, banks or partners.