Global Affairs Canada releases updated sanctions compliance guidance

In November 2025, the Sanctions Bureau of Global Affairs Canada (GAC) released additional guidance on compliance with Canada’s sanctions regime. This is the first formal guidance GAC has provided since a spring 2024 update to its Frequently Asked Questions page, which we previously wrote about.

The new guidance is organized into three sections, covering: 

• Essential information on sanctions legislation, measures, permits, and enforcement.
• Compliance program implementation.
• “Red flag” indicators in due diligence checks.

The guidance aims to help entities understand and meet their sanctions obligations. The guidance remains high level, repeats much of GAC’s existing materials, and provides limited practical direction on how to interpret ambiguous regulatory requirements. 

GAC’s additional guidance includes:  

• Sanctions compliance programs: GAC recommends that compliance programs should include commitment from senior management; risk assessments; internal controls, policies and procedures; testing and auditing of program effectiveness; and training.
  
  However, GAC’s guidance is lacking when compared to the more robust guidance provided by the United States’ OFAC or the United Kingdom’s OFSI.
  
  We can help you prepare, implement, and maintain effective compliance frameworks, including related to sanctions and export control risks. One key element is that the program must be tailored to your organization’s risk profile and consider where your biggest sanctions compliance risks may lie. 

• Non-exhaustive list of red flag indicators: GAC’s due diligence best practices include a non-exhaustive list of circumstances that GAC considers red flags. These red flags include: 
  • changes in business ownership or structure, 
  • links to designated persons, 
  • obscure or undisclosed end-users or end-uses, 
  • the location of parties or activities in countries subject to restrictive measures, and 
  • complex financial or shipping arrangements. 

The guidance is a step in the right direction, but it does not discuss several significant compliance issues, such as the ambiguity surrounding and interpreting the “deemed ownership” provisions. 

The guidance provides some insight into GAC’s position and approach. However, companies should not rely solely on the guidance. Entities should seek legal advice when interpreting sanctions legislation and implementing an adequate compliance program. 

Our team of experienced sanctions and export control lawyers can help your business implement a comprehensive compliance program and conduct due diligence to meet its Canadian sanctions obligations, consistent with GAC’s guidance and applicable non-Canadian sanctions laws.

The authors would like to thank Manreet Brar, articling student, for her contribution to preparing this legal update.