Sudan Sanctions Permit Authorization

Summary#

The Canada Gazette published the Special Economic Measures (Sudan) Permit Authorization Order: SOR/2024-62. The order, registered as P.C. 2024-288 on April 12, 2024 and published April 24, 2024, lets the government give permits for activities that the Sudan sanctions rules would otherwise block.

What it does#

• Authorizes the Minister of Foreign Affairs to issue permits to any person in Canada or any Canadian outside Canada to carry out a specified activity or any class of activity that is restricted or prohibited under the Special Economic Measures (Sudan) Regulations.
• Does not itself list which activities will be allowed. The details of permitted activities depend on the regulations and on individual permits.
• Notes that a Regulatory Impact Analysis Statement is available (it appears after SOR/2024-61 in the Canada Gazette).

Who's affected#

• Businesses and individuals in Canada who deal with Sudan or Sudan-related transactions.
• Canadians outside Canada who might engage in activities connected with Sudan.
• Banks, exporters, freight companies, lawyers, humanitarian groups, and others who may need a permit or must comply with the regulations.
• It is not fully clear from the order which specific activities will be authorized; that depends on the related regulations and permits.

Why it matters#

• This order creates a legal path for exceptions to Sudan-related sanctions on a case-by-case basis.
• That can matter for humanitarian aid, legal transactions, business contracts, financial transfers, or other activities that would otherwise be blocked.
• People and organizations exposed to Sudan-related restrictions will need to watch for permit rules and apply to the Minister of Foreign Affairs if they want an exception.