New Sudan Sanctions: 2 Individuals, 4 Entities

Summary#

The Special Economic Measures (Sudan) Regulations are a new Canadian sanctions rule that came into force on April 12, 2024. It adds 2 individuals and 4 companies to a Canadian sanctions list and prevents many kinds of financial and commercial dealings with those listed.

What it does#

The Special Economic Measures (Sudan) Regulations do these main things:

• Add specific people and companies to Canada’s list of sanctioned persons.
• Prohibit anyone in Canada, and Canadians abroad, from:
  • dealing in property owned or controlled by a listed person;
  • entering or facilitating transactions involving that property;
  • providing financial or related services to a listed person;
  • supplying goods or transferring property to a listed person.
• Require a range of financial and related institutions (banks, credit unions, insurers, trust companies, securities firms and similar businesses) to keep checking whether they hold property of a listed person and to disclose holdings or suspicious transactions without delay to the Royal Canadian Mounted Police or the Canadian Security Intelligence Service.
• Let listed people apply to the Minister of Foreign Affairs to be removed from the list, and create a process for people who claim mistaken identity.
• Include exceptions for humanitarian work, diplomatic missions, some pre‑existing contracts and certain international organizations. The Minister may also issue permits that allow specific otherwise‑prohibited activities.
• Create criminal penalties for knowingly breaking the rules: a fine of up to $25,000 or imprisonment up to 1 year on summary conviction, or imprisonment up to 5 years on indictment.

Who's affected#

People and organizations most likely to notice this change:

• The specific persons and companies added to the schedule:
  • Individuals: Abdelrahim Hamdan Dagalo and Ali Karti.
  • Companies: Al Junaid Multi Activities Co. Ltd., GSK Advance Company Ltd., Defence Industries System, and Zadna International Company for Investment Ltd.
• Financial institutions, credit unions, insurers, trust and loan companies, securities dealers and similar businesses in Canada. They must screen for and report any assets or transactions linked to the listed persons.
• Canadians and people in Canada who might otherwise do business with the listed persons. They will be prohibited from certain dealings and may need to seek a permit for permitted exceptions.
• Humanitarian organizations and diplomatic missions are explicitly covered by exceptions, so typical emergency relief activities can still proceed if they meet those rules.

If it is unclear who is affected in a specific case, organizations should review the full regulation or contact Global Affairs Canada for guidance.

Why it matters#

• These regulations freeze and block normal financial and commercial channels for the named people and companies. That reduces their ability to get money, goods or services that could support conflict or human rights abuses.
• The measures aim to increase pressure on parties linked to the conflict in Sudan to stop fighting and to comply with human rights and international law. Canada says the conflict has caused major humanitarian harm, including about 6.5 million people displaced inside Sudan and over 1.9 million who have fled to neighbouring countries.
• Canada has also been providing humanitarian help and development funds (for example, about $170 million in 2023, including roughly $42 million for assistance inside Sudan and an additional $6 million in development funding). The regulations include exceptions so that these kinds of lifesaving activities can continue.
• For everyday businesses in Canada the impact is likely to be small, because the government believes the newly listed people and companies have limited ties to Canada. Still, banks and other institutions must update screening and reporting systems to stay compliant.
• Being listed can also affect travel: listed individuals will be considered inadmissible under the Immigration and Refugee Protection Act, and enforcement can involve the RCMP and border authorities.