Documentation · Canada

Special Economic Measures Act (SEMA)

SEMA lets Canada impose sanctions on foreign states, individuals and entities through country regulations. For a business, a listing means an asset freeze and a ban on dealing with the listed person. It also means a duty to check your holdings and report to the RCMP or CSIS without delay. This page sets out the rules as published by the Government of Canada and shows where to find the official lists in Crown Intelligence.

Sources read 2026-10-10. Citations appear in square brackets and are listed under Sources.

What SEMA is

The Special Economic Measures Act (SEMA) is Canada's main statute for autonomous economic sanctions [1][5]. The Governor in Council may make orders and regulations against a foreign state when one of four circumstances applies: an international organization or association of states of which Canada is a member calls on its members to act; a grave breach of international peace and security has occurred; gross and systematic human rights violations have been committed in a foreign state; or a foreign public official, or an associate, is responsible for significant corruption [1, s. 4(1.1)].

Each country regime is set out in its own regulations. Examples on the Government of Canada list include Belarus, Iran, Myanmar and Russia [4]. The Minister of Foreign Affairs administers and enforces SEMA, apart from the financial-institution provisions in Part 2, which the Minister of Finance administers [1, s. 6(1), s. 16]. Canada's separate tools are the United Nations Act and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) [4].

Who it applies to

The prohibitions apply to any person in Canada and to any Canadian outside Canada [2, s. 3]. A "Canadian" is a citizen under the Citizenship Act or a body corporate incorporated or continued under the laws of Canada or a province [1, s. 2]. Some duties fall on specific sectors. Under the Russia Regulations, the duty to determine holdings applies to listed financial and insurance entities, including authorized foreign banks, the Bank of Canada, credit unions and caisses populaires, insurance and trust and loan companies, and firms that open accounts for clients or deal in securities [2, s. 6]. The duty to disclose applies to every person in Canada and every Canadian outside Canada [2, s. 7].

What a listing means

A listing creates a dealings prohibition and an asset freeze. Under the Russia Regulations, no person in Canada or Canadian abroad may deal in property owned, held or controlled by or on behalf of a listed person, enter into or facilitate a related transaction, provide a related financial or other service, make goods available to a listed person, or provide a financial or related service to or for the benefit of a listed person [2, s. 3]. Knowingly causing, facilitating or assisting a prohibited activity is also an offence [2, s. 5]. Canada's guidance describes the freeze as a bar on access to property or other assets [4][5].

Ownership and control matter. Under SEMA, a person controls an entity if the person holds 50% or more of its shares or voting rights, can change the composition or powers of its board, or can reasonably be concluded to direct its activities. Property held by a controlled entity is then deemed owned by that person [1, s. 2.1]. Ownership and control rules for each regime are in the regulations, so check the specific schedule before you act.

Other prohibitions depend on the regime. They can cover financial prohibitions such as wire transfers and letters of credit, export and import restrictions, arms embargoes and technical-assistance bans [4][5]. The regulations for each country set the exact scope.

What it requires of a business

Determine on a continuing basis. Covered financial and insurance entities must check whether they hold or control property of a listed person [2, s. 6].
Disclose without delay. Any person must disclose to the Commissioner of the RCMP or the Director of CSIS the existence of property they have reason to believe is owned or controlled by a listed person, or by an entity that a listed person owns or controls. They must also disclose information about any actual or proposed transaction involving that property [2, s. 7(1)]. Good-faith disclosures carry immunity from proceedings under SEMA and civil proceedings [2, s. 7(2)].
Report to FINTRAC. Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) must report to FINTRAC as soon as practicable once they have reasonable grounds to suspect a transaction is related to a sanctions evasion offence. Canada's guidance states that failure to report is an offence, with a fine of up to $1,000,000 on summary conviction under PCMLTFA s. 77(1) [5].
Record-keeping. The SEMA and Russia Regulations read for this page do not set a retention period. Keep records of screening, determinations and disclosures as part of your compliance programme. Canada's compliance guidance is at [7].
Avoid evasion. Canada's red-flag guidance lists common signs of suspicious transactions or sanctions evasion [5][7].

Penalties and enforcement

A person who wilfully contravenes an order or regulation under SEMA s. 4 is guilty of a summary offence, with a fine of up to $25,000, up to one year in prison, or both. Under the indictable route, the maximum is five years in prison [1, s. 8]. Proceedings require the consent of the Attorney General of Canada [1, s. 12]. Peace officers may search without a warrant in exigent circumstances and seize evidence [1, s. 9(2)]. The RCMP and the Canada Border Services Agency enforce the regime, and FINTRAC financial intelligence supports those investigations [5]. Property can be seized, restrained and, after a court process, forfeited [1, s. 4(1)(b), s. 5.4].

The official lists involved

The Consolidated Canadian Autonomous Sanctions List brings together persons listed under SEMA and the JVCFOA. It is published by Global Affairs Canada in HTML, PDF and XML [6]. The list itself is administrative. It is not a regulation and does not have force of law, so the regulation that applies to a named person and the provisions that apply to that person must be checked [6].

Other lists you may need include the country-specific schedules in each SEMA regulation, the United Nations consolidated list used under the United Nations Act [3][4], and the Criminal Code list of terrorist entities, which is a separate instrument [3]. Canada's delisting and mistaken-identity processes are in the Russia Regulations. A person may apply in writing to the Minister to be removed from a schedule, and the Minister decides whether to recommend removal [2, s. 8]. A person with a name similar to a listed person may apply for a certificate of mistaken identity. The Minister must decide within 30 days after receiving the application [2, s. 9].

Permits and exemptions

SEMA allows the Governor in Council to authorize the Minister of Foreign Affairs to issue permits for a specified activity or transaction, or a general permit for a class of them, that a regulation would otherwise prohibit. The Minister may attach terms and may amend, suspend, revoke or reinstate a permit [1, s. 4(4) to (6)]. Canada describes permits as exceptional, case-by-case decisions at the Minister's discretion [5]. Certificates, a different instrument, apply to UN Act measures. Each regulation also sets its own exclusions. For example, section 4 of the Russia Regulations lists activities to which the prohibition in section 3 does not apply [2, s. 4]. Applications and required documents are set out on Global Affairs Canada's permits and certificates page [3][5]. Exports to countries named in the Area Control List need an export permit issued under the Export and Import Permits Act [5].

How Crown Intelligence covers it

Crown Intelligence holds the Canadian consolidated list and the other SEMA and JVCFOA schedules as separate registers. Each register is credited to its publisher, dated, and refreshed on its own schedule. The live row counts below are read from the Crown Intelligence source API when this page loads.

Register	Instrument	Rows (live)	Last loaded
Consolidated Canadian Autonomous Sanctions List (SEMA and JVCFOA)	SEMA, JVCFOA	Loading	-
Justice for Victims of Corrupt Foreign Officials (Magnitsky) Regulations, schedule of foreign nationals	JVCFOA	Loading	-
SEMA (Hamas Terrorist Attacks) Regulations, schedule	SEMA	Loading	-

To see every Canadian sanctions register, open the source list filtered to Canada or filtered to SEMA. Confirm every match against the regulation before you act on it.

Practical checklist

Screen customers, counterparties, beneficial owners and payees against the consolidated list and the regime-specific schedules you are subject to.
Apply the 50% and control tests in SEMA s. 2.1 when you assess ownership.
Freeze or block property of a listed person and stop any prohibited dealing, service or transaction. Do not wait for a formal notice.
Disclose to the RCMP or CSIS without delay when you have reason to believe property is held for a listed person.
If you are a reporting entity under the PCMLTFA, assess whether you have reasonable grounds to suspect sanctions evasion and report to FINTRAC as soon as practicable.
Check the date of the list version you use, and re-screen when the list changes.
Ask whether a permit or certificate could cover a planned activity, and apply before proceeding.
Record each decision, the source checked and its date.

Frequently asked questions

Is a name on the consolidated list the same as a legal listing?

The list is an administrative consolidation. It is not a regulation and has no force of law. The regulation that applies to the named person, and the provisions in its schedule, decide what is prohibited [6].

Do I have to report if I only suspect a link to a listed person?

The SEMA disclosure duty applies when a person has reason to believe property is owned or controlled by a listed person, and it must be made without delay to the RCMP or CSIS [2, s. 7]. Reporting entities must also report to FINTRAC once they have reasonable grounds to suspect sanctions evasion [5].

Can we deal with a listed person if we have a permit?

Only to the extent the permit allows, and only under its terms. Permits are issued at the Minister of Foreign Affairs' discretion, and the Minister may amend, suspend or revoke them [1, s. 4(4) to (6)] [5].

What if a client has the same name as a listed person?

The person may apply in writing for a certificate of mistaken identity. The Minister must decide within 30 days after receiving the application [2, s. 9].

How is ownership or control of an entity treated?

A person who holds 50% or more of an entity's shares or voting rights, can change its board, or can reasonably be concluded to direct its activities, controls it. Property held by that entity is then deemed owned by the person [1, s. 2.1].

What are the penalties?

For a wilful contravention, the summary penalty is a fine of up to $25,000, up to one year in prison, or both. The indictable penalty is up to five years in prison. Prosecutions need the Attorney General's consent [1, s. 8 and s. 12].

Sources

Government of Canada, Special Economic Measures Act (S.C. 1992, c. 17), laws-lois.justice.gc.ca, https://laws-lois.justice.gc.ca/eng/acts/S-14.5/FullText.html. Current to 2026-09-21. Read 2026-10-10.
Government of Canada, Special Economic Measures (Russia) Regulations (SOR/2014-58), laws-lois.justice.gc.ca, https://laws-lois.justice.gc.ca/eng/regulations/SOR-2014-58/FullText.html. Current to 2026-09-21. Read 2026-10-10.
Global Affairs Canada, "Canadian sanctions", https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/index.aspx?lang=eng. Page date modified 2026-10-09. Read 2026-10-10.
Global Affairs Canada, "Current sanctions imposed by Canada", https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/current-actuelles.aspx?lang=eng. Page date modified 2024-07-05. Read 2026-10-10.
Global Affairs Canada, "Canadian sanctions - Essential information", https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/essential-informations-essentielles.aspx?lang=eng. Page date not shown in the copy read. Read 2026-10-10.
Global Affairs Canada, "Consolidated Canadian Autonomous Sanctions List", https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/consolidated-consolide.aspx?lang=eng. List last updated 2026-09-22 as stated on the page. Read 2026-10-10.
Global Affairs Canada, "Canadian sanctions - Information and guidance", https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/guidance-orientation.aspx?lang=eng. Page date modified 2026-03-16. Read 2026-10-10.

Not legal advice. This page summarizes public government sources for general information. It does not interpret the law for your situation. Check the regulation that applies to a person or transaction, and speak with qualified counsel before you act.

Last updated 2026-10-10