Documentation · Canada

United Nations Act sanctions

Canada puts UN Security Council sanctions into domestic law through the United Nations Act. In practice a business must not deal with a listed person or their property, must hold or freeze what it controls, must disclose it to the RCMP or CSIS without delay, and, if it is a FINTRAC reporting entity, must report suspected sanctions evasion. Breaches are criminal offences.

What the United Nations Act is

The Act lets the Governor in Council make orders and regulations when the UN Security Council decides on a measure under Article 41 of the UN Charter and calls on Canada to apply it [1]. Each UN regime is set out in its own regulation, with its own list, prohibitions and exceptions [2][3][4][5][6].

Who it applies to

The prohibitions apply to every person in Canada and to every Canadian outside Canada [2][3]. Under these regulations, a Canadian is a citizen, or a body corporate incorporated or continued under federal or provincial law [2][3]. Some regulations also place a continuing duty on banks, authorized foreign banks, credit unions, insurers, trust and loan companies and securities dealers to check whether they hold property of a listed person [2][3].

How UN listings take effect in Canada

Most UN regulations do not contain their own names. They refer to the names the relevant Security Council committee publishes, so a person falls within the Canadian prohibitions once the committee lists them [2][8]. The exception is the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism, which names its persons in a schedule [3][8].

Each committee publishes its own list and the measures that apply to each name. Member States must apply the measures stated for each listed name on the committee's website [13]. The UN's consolidated list gathers all these names in one place, but its inclusion of a name neither means that one regime applies nor that the same criteria apply to every name [13].

The UN regimes in Canadian regulations

Global Affairs Canada (GAC) maintains the list of current regimes [7]. The main UN-based regulations for businesses are summarized below.

What it requires of a business

Prohibited activity

• Dealing in property owned, held or controlled, directly or indirectly, by a listed person, or by someone acting for them [2][3].
• Entering into or facilitating a transaction related to such dealings [2][3].
• Providing financial or related services in respect of that property, or making property or services available to, or for the benefit of, a listed person [2][3].
• Knowingly causing, facilitating or assisting an activity that is prohibited [2][3].
• Knowingly providing or collecting funds for a listed person, under the Taliban, ISIL and Al-Qaida regulation and the terrorism regulation [2][3].
• The prohibitions apply to knowing conduct, so a business should show what it knew and what checks it made [2][3][9].

Duty to check and to disclose

• Regulated financial, insurance, trust and loan entities must determine on a continuing basis whether they hold property of a listed person [2][3].
• Every person in Canada and every Canadian abroad must disclose without delay to the RCMP Commissioner or the Director of CSIS the existence of property they have reason to believe is owned or controlled by a listed person, and any information about a related transaction [2][3][10]. Disclosures made in good faith carry immunity from proceedings [2][3].
• Reports go to the RCMP's Federal Policing Intake, which is the main point of contact for sanctions disclosures [9][10].

Reporting suspected sanctions evasion

• Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act must report to FINTRAC any completed or attempted transaction where there are reasonable grounds to suspect it is related to a sanctions evasion offence [9][12].
• FINTRAC's Special Bulletin on financial activity associated with suspected sanctions evasion sets out red flags to help identify such activity [12].
• FINTRAC lists ministerial directives in force for Russia, Iran and the DPRK, each with its own obligations [12].

Records and due diligence

GAC recommends that businesses document their assessment, decisions and any legal advice, so that they can show reasonable due diligence if a contravention is alleged [9]. The regulations reviewed here do not set a separate record-keeping period for these duties [2][3].

Exceptions and certificates

• Humanitarian assistance. The Taliban, ISIL and Al-Qaida regulation allows funds, assets and services needed for timely humanitarian assistance, when provided by specified groups such as UN agencies, international organizations and certain non-governmental organizations [2]. Similar carve-outs were added to the DPRK and Libya regulations in 2023, following UN Security Council Resolution 2664 (2022) [5][6].
• Exemption certificates. A person who wants to do something prohibited must apply to the Minister in writing before acting. The Minister must issue a certificate where the Security Council did not intend the activity to be prohibited, or where the Security Council or the relevant committee has approved it in advance [2][3].
• Basic and extraordinary expenses. A certificate may be issued for property needed for basic or extraordinary expenses, within the working-day deadlines in the regulations [2][3].
• Mistaken identity. A person whose name is the same as or similar to a listed person may apply for a certificate stating they are not that person. The Minister must decide within 45 working days [2][3][8].

Penalties

• Under the United Nations Act, a summary conviction carries a fine of up to $100,000, up to one year in prison, or both. On indictment the maximum is 10 years in prison [1][9].
• Property dealt with contrary to a regulation may be seized and forfeited on proceedings in the Federal Court or a superior court [1].
• Failing to report under the PCMLTFA carries a fine of up to $1,000,000 on summary conviction [9].
• The CBSA and the RCMP enforce the rules, and FINTRAC's financial intelligence supports their investigations [9].

The official lists

The Canadian consolidated list does not include names from UN regimes. For UN regimes, use the UN list and the relevant regulation [8][13].

How Crown Intelligence covers it

We publish the UN and Canadian registers below as separate sources, each credited to its publisher and dated. Counts are read live from our data service, not typed in. Each record names its register, so a match can be traced to the list it came from.

A name match against these registers is a reason to review, not a legal finding. Confirm the regime, the listing and the applicable prohibitions in the regulation before acting [8][9]. Crown Intelligence does not decide who is listed, and we do not give legal advice.

Practical checklist

1. Subscribe to GAC's sanctions email alerts so you hear about regulation changes [9].
2. Screen customers, counterparties, owners, directors, payees and intermediaries against the UN consolidated list and the Canadian lists above [9][13].
3. When there is a match, identify the regime and read the regulation that applies to it [8][9].
4. Check indirect exposure, including associates, family members, legal representatives, subsidiaries, parent companies and intermediary banks [9].
5. If you hold property of a listed person, stop dealing with it and disclose it to the RCMP or CSIS without delay [2][3][10].
6. If an activity would otherwise be prohibited, apply for a certificate before acting [2][3].
7. If you are a FINTRAC reporting entity, assess whether you have reasonable grounds to suspect sanctions evasion and file a suspicious transaction report [12].
8. Document your checks, decisions and any legal advice [9].
9. Re-screen when the UN or Canadian lists change. The UN list was last updated on 5 October 2026 [13].
10. Get legal advice on any unclear case. GAC cannot give legal advice to the public [5][9].

Frequently asked questions

Does a UN listing apply in Canada without a Canadian listing?

For most UN regimes, yes. The Canadian regulation refers to the names the UN committee publishes, so no separate Canadian listing is needed [2][8]. The terrorism suppression regulation is the exception, because it names its persons in its own schedule [3][8].

Is the Canadian consolidated list the same as the UN list?

No. The Canadian consolidated list covers names in regulations made under the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act. It is for reference only and has no force of law [8]. For UN regimes, check the UN list and the regulation [8][13].

Must I report to the RCMP if I am not a bank?

Yes, if you have reason to believe you hold property owned or controlled by a listed person. Under most UN and Special Economic Measures Act regulations, any person in Canada, and any Canadian abroad, must disclose it without delay to the RCMP Commissioner or the Director of CSIS [2][3][10].

What are the penalties for breaking a UN regulation?

On summary conviction under the United Nations Act, the maximum is a $100,000 fine, one year in prison, or both. On indictment, the maximum is 10 years in prison. Property may also be forfeited [1][9].

How do I get removed from a UN list?

For UN committee listings, apply to the UN Focal Point for Delisting, or for ISIL (Da'esh) and Al-Qaida listings to the Office of the Ombudsperson. You can also send the request through GAC's Sanctions Bureau [8]. For the terrorism suppression regulation, apply in writing to the Minister of Foreign Affairs. A refusal can be taken to judicial review [3][8].

What if my name matches a listed person, but I am not that person?

Apply to the Minister of Foreign Affairs for a certificate of mistaken identity. The Minister must decide within 45 working days [2][3][8].

Sources

All sources were read on 2026-10-10. Pages are cited by the date each was last modified, as shown on the page.

1. United Nations Act (R.S.C., 1985, c. U-2). Justice Laws Website. laws-lois.justice.gc.ca/eng/acts/U-2/FullText.html. Current to 2026-09-21.
2. Regulations Implementing the United Nations Resolutions on Taliban, ISIL (Da'esh) and Al-Qaida (SOR/99-444). Justice Laws Website. laws-lois.justice.gc.ca/eng/regulations/SOR-99-444/FullText.html. Current to 2026-09-21.
3. Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism (SOR/2001-360). Justice Laws Website. laws-lois.justice.gc.ca/eng/regulations/SOR-2001-360/FullText.html. Current to 2026-09-21.
4. Regulations Implementing the United Nations Resolutions on Iran (SOR/2007-44). Justice Laws Website. laws-lois.justice.gc.ca/eng/regulations/SOR-2007-44/index.html. Current to 2026-09-21; last amended 2025-09-30.
5. Canadian Sanctions Related to North Korea. Global Affairs Canada. international.gc.ca (korea-coree). Last modified 2025-03-25.
6. Canadian Sanctions Related to Libya. Global Affairs Canada. international.gc.ca (libya-libye). Last modified 2024-07-15.
7. Current sanctions imposed by Canada. Global Affairs Canada. international.gc.ca (current-actuelles). Last modified 2024-07-05.
8. Listed persons, mistaken identity and delisting. Global Affairs Canada. international.gc.ca (listed_persons). Last modified 2025-11-26.
9. Canadian sanctions – Essential information. Global Affairs Canada. international.gc.ca (essential-informations-essentielles). Last modified 2026-10-09.
10. Canadian sanctions – Dealings prohibition and asset freeze. Global Affairs Canada. international.gc.ca (dealings-prohibition-interdiction-operations). Last modified 2026-03-17.
11. Canada announces implementation of UN sanctions against Iran over nuclear proliferation activities. Global Affairs Canada news release, 2025-10-01. canada.ca (news release).
12. Report suspected sanctions evasion. FINTRAC. fintrac-canafe.canada.ca (sanctions-eng). Last modified 2025-02-10.
13. UN Security Council Consolidated List. United Nations Security Council. main.un.org (un-sc-consolidated-list). Page states the list was last updated on 5 October 2026.
14. Canadian sanctions (home page). Global Affairs Canada. international.gc.ca (sanctions index). Last modified 2026-10-09.

Not legal advice. This page explains Canadian UN sanctions rules for general information. It does not decide whether any particular activity is lawful. Read the regulation that applies, and speak with a lawyer before acting on an unclear case.

Last updated 2026-10-10