Canada’s Deemed Ownership Guidance

Aggregation, Influence and Transfers to Associates

Posted 10/16/26

Global Affairs Canada (GAC) has published guidance on Canada’s sanctions deemed ownership provisions, addressing when a listed person’s control of an unlisted entity can bring that entity’s property within sanctions restrictions. The guidance warrants attention from financial institutions, businesses and counsel assessing counterparties with complex ownership or governance arrangements.

This item is available in full to subscribers.

Please log in to continue

Log in