As a result of their deliberations committees may make recommendations which they include in their reports for the consideration of the House of Commons or the Government. Recommendations related to this study are listed below.

The Administration of Canada’s Sanctions Regime

Recommendation 1

That the Government of Canada provide detailed explanations for all measures imposed pursuant to its autonomous sanctions legislation, including specific rationales for the listing of individuals and entities under the relevant regulations.

Recommendation 2

That the Government of Canada ensure that its Consolidated Canadian Autonomous Sanctions List is user-friendly, searchable and regularly updated, and that each entry includes the information necessary for compliance activities and the rationale for the designation.

Recommendation 3

That, within a reasonable time frame, the Government of Canada publish more detailed written guidance on its autonomous sanctions legislation and regulatory measures adopted pursuant to this legislation to enable and enhance sanctions compliance.

Recommendation 4

That the Government of Canada publish comprehensive information for the public outlining the processes by which sanctions are imposed and by which exemption permits may be issued, and that it update this information as appropriate.

Recommendation 5

That the Government of Canada institute service standards for the processing of permit applications pursuant to its autonomous sanctions legislation, while respecting the exceptional nature of permits and the scrutiny required.

Recommendation 6

That the Government of Canada adopt clear, consistent, and comprehensive humanitarian carve-outs across its sanctions regimes and related legislation, in line with international humanitarian law and relevant resolutions of the United Nations Security Council.

Recommendation 7

That the Government of Canada publish detailed written guidance explaining the humanitarian carve-outs in its sanctions regimes, consistent with the protection of impartial humanitarian action under international humanitarian law.

Recommendation 8

That the Government of Canada explore the establishment of an external consultative body on sanctions, including representatives from civil society, the financial sector and the private sector, which would meet regularly, advance meaningful dialogue on Canada’s sanctions regime, and develop an effective process for collecting feedback and documentation.

The Governance and Resourcing of Canada’s Sanctions Regime

Recommendation 9

That the Government of Canada report to Parliament on the implementation and results of the $76 million that was announced in October 2022 to strengthen Canada’s capacity to implement its sanctions.

Recommendation 10

That the Government of Canada allocate budgetary resources to the sanctions units within Global Affairs Canada, the Royal Canadian Mounted Police, the Canada Border Services Agency, and all other implicated departments and agencies, at a level commensurate with the growing importance of sanctions policy and the increasing complexity and challenges associated with sanctions implementation and enforcement.

Recommendation 11

That the Government of Canada reinforce specialized training programs on sanctions for all implicated personnel.

Recommendation 12

That, as part of the expansion in budgetary and training resources recommended above, the Government of Canada take specific steps to further strengthen the capacity of the Royal Canadian Mounted Police and the Canada Border Services Agency to enforce Canada’s sanctions regime.

Recommendation 13

That, building on the recommendation contained in the 2017 report of the House of Commons Standing Committee on Foreign Affairs and International Development – entitled A Coherent and Effective Approach to Canada’s Sanctions Regimes: Sergei Magnitsky and Beyond – and in light of developments since that time, the Government of Canada review the way in which it is administering its autonomous sanctions legislation and the Export and Import Permits Act to ensure it is maximizing the efficiency, effectiveness, and resourcing of their complementary aspects. The review should seek to determine whether the separate units in Global Affairs Canada that are responsible for administering this legislation should be amalgamated in whole or in part.

Recommendation 14

That the Government of Canada, in collaboration with international partners and working closely with other relevant law enforcement agencies, develop a strategy to address sanctions violations – including offshore export havens and jurisdiction shopping – while increasing the enforcement of existing controls.

Recommendation 15

That, within a reasonable time frame, the Government of Canada conduct a comprehensive review of the departmental and agency mandates, authorities, coordination mechanisms and reporting relationships supporting its sanctions regime, with equal emphasis given to the needs and challenges associated with sanctions policy, administration, and enforcement, and that it publish the results. As well, in the process of conducting this comprehensive review, that the Government of Canada consider other models or systems in place used by allies to enforce, coordinate, and monitor sanctions.

Recommendation 16

That, in Budget 2024, the Government of Canada provide details on the structure and mandate of the proposed Canada Financial Crimes Agency.

Recommendation 17

That the Government of Canada consider designating a unit within the proposed Canada Financial Crimes Agency responsible for sanctions enforcement.

Recommendation 18

That the Government of Canada publish comprehensive data annually on Canadian exports of dual-use goods, as it does for military goods, including the value of those exports, descriptions of the goods, and their authorized end users.

The Multilateral Coordination of Canada’s Sanctions Regime

Recommendation 19

That the Government of Canada increase its investment in dedicated capacity for sanctions diplomacy with the objective of maximizing the number of partners that are applying the same or similar sanctions measures, closing any implementation gaps that may exist, and countering any sanctions circumvention that may be taking place.

The Effectiveness of Canada’s Sanctions Regime

Recommendation 20

That the Government of Canada present an annual report to Parliament on its autonomous sanctions, including an overview of the objective and assessed impact of each regime established in relation to a foreign state, alongside a summary of the amount of assets in Canada that have been effectively frozen and transactions that have been blocked and any seizure or restraint orders that have been made, as can be publicly disclosed in accordance with the Privacy Act and the protection of Canada’s national security interests.

Recommendation 21

That the Government of Canada review its autonomous sanctions on a regular basis to ensure that the measures are calibrated precisely to achieve each regime’s intended objective and that the associated designations remain appropriate.

The Coherence and Consistency of Canada’s Sanctions Regime

Recommendation 22

That the Government of Canada review its autonomous sanctions legislation to determine whether any harmonization or further elaboration of its human rights and corruption triggers is required.

Recommendation 23

That the Government of Canada review its autonomous sanctions legislation and the approaches of like-minded jurisdictions to identify best practices and ensure that Canada’s legislative framework corresponds to Canada’s interests and commitments in relation to national security, foreign policy, and human rights and is designed in a way that enables the government to address the full range of circumstances in which the imposition of sanctions may be required.