RECOMMENDATION 1

The Government of Canada should work with its allies to establish a formal mechanism for the coordination and implementation of autonomous sanctions and for the sharing of best practices on how to maximize sanctions effectiveness.

RECOMMENDATION 2

The Government of Canada should seek to be consistent in its global application of autonomous sanctions imposed in response to human rights violations.

RECOMMENDATION 3

The Government of Canada should provide clear policy guidance surrounding its authority to use the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), including by articulating the circumstances in which either Act may be used and the rationale for using one Act over the other.

RECOMMENDATION 4

The Government of Canada should specifically outline the objectives associated with a given sanctions regime and clearly communicate those objectives to the public.

RECOMMENDATION 5

The Government of Canada should work with its allies, civil society and the academic and research community to develop methodology to evaluate the effectiveness and impact of Canadian sanctions, including their effects and any consequences of an unintended nature.

RECOMMENDATION 6

The Government of Canada should regularly review the humanitarian exceptions in Canadian sanctions regulations to ensure that the public has clarity and guidance in relation to the delivery of humanitarian assistance in a state targeted by Canadian sanctions.

RECOMMENDATION 7

As part of establishing a specialized sanctions bureau, the Government of Canada should ensure that the officials involved in administering Canada’s sanctions receive training on the specifics of Canada’s sanctions regimes.

RECOMMENDATION 8

As part of establishing the specialized sanctions bureau, the Government of Canada should expand interdepartmental coordination on sanctions so that all relevant departments and agencies, including the Canadian Security Intelligence Service and the Communications Security Establishment, can contribute to identifying individuals and entities that could be subject to autonomous sanctions by Canada.

RECOMMENDATION 9

The Government of Canada should invest greater financial and human resources in enforcing sanctions by providing new funding specifically for this purpose to the Royal Canadian Mounted Police and the Canada Border Services Agency.

RECOMMENDATION 10

The Government of Canada should provide more detailed identifying information on sanctioned individuals and entities in the regulations made pursuant to the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law). The government should also include detailed identifying information in the Consolidated Canadian Autonomous Sanctions List, along with the justifications for listing individuals and entities.

RECOMMENDATION 11

The Government of Canada should evaluate the feasibility, advantages and disadvantages of having the consolidated list include individuals sanctioned under the United Nations Act, the Freezing Assets of Corrupt Foreign Officials Act and the terrorist entity provisions of the Criminal Code.

RECOMMENDATION 12

The Government of Canada should amend the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) to require the government to table in Parliament a detailed annual report on the implementation of Canada’s sanctions regimes. This report could include information on the impact and effectiveness of Canada’s sanctions regimes and the value of frozen assets and blocked transactions under each sanctions regime.

RECOMMENDATION 13

The Government of Canada should make it a priority to develop and provide the public and the private sector with specific and comprehensive written guidance on the interpretation of Canada’s autonomous sanctions laws and regulations. This guidance should be updated in a regular and timely manner to reflect new regulations made under Canada’s sanctions regimes.

RECOMMENDATION 14

The Government of Canada should evaluate how it could use its existing authority to grant general permits under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

RECOMMENDATION 15

The Government of Canada should establish an effective, transparent process to review applications for delisting with specific service standards. The Government of Canada should also inform individuals and entities subject to autonomous sanctions of the action taken against them, along with an explanation as to why they have been sanctioned and how to submit an application for delisting.

RECOMMENDATION 16

The Government of Canada should establish specific service standards for the processing of permit applications sought in relation to the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

RECOMMENDATION 17

The Government of Canada should engage with its allies, including as part of the Russian Elites, Proxies and Oligarchs Task Force, to share best practices regarding the forfeiture and repurposing of sanctioned assets.

RECOMMENDATION 18

The Government of Canada should amend the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) to require that committees of the Senate and the House of Commons conduct a comprehensive review of the two Acts every 10 years.

RECOMMENDATION 19

The Government of Canada should amend the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) to require that new regulations made under either Act include a sunset clause that would prescribe a date for the termination of a sanctions regime unless renewed prior to the expiry of the term.