Changes to UN sanctions regulations; Mali repealed

Summary#

These are final regulations called Regulations Amending and Repealing Certain Regulations Made Under the United Nations Act (Miscellaneous Program) (SOR/2024-138). They make technical and timing changes to many rules that implement United Nations sanctions and repeal Canada’s sanctions rules for Mali. The instrument was registered on June 17, 2024 and published in the Canada Gazette on July 3, 2024, and it came into force on registration.

What it does#

• Adds clear definitions used across the rules, including working day, Minister and Security Council, and makes time limits count only working days.
  • Some specific time limits changed to 60 working days, 45 working days, 90 working days, 10 working days, or five working days, depending on the rule.
• Makes the Minister’s duty to issue certain exemption certificates mandatory (changes “may” to “must”) in several instruments, including the:
  • Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism
  • Regulations Implementing the United Nations Resolutions on Iraq
  • Regulations Implementing the United Nations Resolutions on Iran
  • Regulations Implementing the United Nations Resolution on Lebanon
  • Regulations Implementing the United Nations Resolutions and Imposing Special Economic Measures on Libya
  • Regulations Implementing the United Nations Resolutions on Yemen
• Clarifies and harmonizes language about legal protections (for example, against self-incrimination) and legal proceedings in several regulations, including the Iraq, Central African Republic, Libya and Yemen instruments.
• Fixes wording differences between English and French on the term “armed mercenaries” in the Libya and Yemen regulations.
• Replaces an out-of-date reference to a specific government director with the more permanent reference Minister in the Iraq regulations.
• Changes the titles of the Lebanon and Haiti regulations to use the plural “Resolutions” for consistency.
• Repeals the Regulations Implementing the United Nations Resolutions on Mali, because the UN Security Council’s Mali sanctions regime ended on August 31, 2023.

Who's affected#

• People and groups directly targeted by UN sanctions and anyone dealing with their property in Canada (for example, banks, lawyers and trustees).
• Exporters or suppliers of military or protective equipment who must notify authorities before certain shipments (the rules mention a five working day notice for some non-lethal military equipment).
• Global Affairs Canada, which administers and decides on many of the certificates and notices the regulations require.
• Persons or entities that had measures under the Mali regulations: those Canadian rules were repealed, so people formerly affected by the Mali listing will no longer be subject to those specific Canadian prohibitions.
• The government says Canadian small businesses will not be affected.

Why it matters#

• The changes reduce ambiguity. Clear definitions and working-day time limits make deadlines easier to understand and apply.
• Making certificate issuance mandatory when conditions are met limits administrative discretion. That can speed up predictable approvals for activities the UN allows.
• Repealing the Mali regulations aligns Canada with the United Nations: when the UN sanctions regime ended on August 31, 2023, Canada removed the matching domestic rules.
• Fixing wording differences between English and French and replacing outdated job titles reduces the need for future technical fixes and confusion in enforcement.