Under-resourced sanctions regime leaves Ottawa in the dark: internal review

By Canadian Press on September 16, 2025.

OTTAWA — The federal government’s enthusiasm for laying sanctions on thousands of foreigners has made it harder for Canadians to understand and comply with the sanctions regime and exposes Ottawa to lawsuits, an internal review says.

The findings come as the Conservatives call for Canada to slap sanctions on those behind transnational repression.

“The urgency and frequency of new sanctions packages put intense pressure on operations, limited the ability to conduct research to further support listings and other decisions, and created legal risks,” reads the internal evaluation report dated March 2025.

The report says the “acutely understaffed” sanctions teams can’t respond in a timely matter to requests for exemptions and removal from sanctions lists.

The report says Global Affairs Canada is also “an international and domestic outlier” because it doesn’t provide clear guidance to businesses and the public on how to not break the law when doing business abroad, or on navigating transfers like child-support payments from Russia.

This “increases the likelihood of unintended impacts on Canadians, non-Canadians and Canada’s interests abroad,” says the report.

It suggests a legislative overhaul, citing “inadequate resources and capacity, lack of systems, and lack of a comprehensive approach” to sanctions.

Global Affairs Canada has accepted almost all of the report’s findings and has promised to improve its reporting to the public and the processes for appealing sanctions.

The department launched its sanctions division in 2018 and expanded it to a bureau in 2023, due to the steep increase in federal sanctions in response to Russia’s full-scale invasion of Ukraine in February 2022.

Ottawa had earmarked $76 million to boost sanctions administration and enforcement by fall 2022, and expanded the division from 13 to 50 full-time staff.

Canada issued just eight sanctions packages in the financial year that ended in March 2019. It issued 55 in the year ending in spring 2023.

Sanctions have gone from “a foreign-policy tool of last resort” to “a preferred option that is used early on, to address a range of international issues,” the report says.

Much of the work of determining who gets sanctioned falls on the geographic desks at Global Affairs. Those desks “know the country context but do not necessarily have human-resource capacity for this specialized and frequently urgent research,” the report says, adding a lack of forensic accounting and business knowledge has made it “time-consuming and difficult for GAC staff” to review applications for sanctions exemptions.

Unlike Canada, the U.K. publishes a specific summary of the acts every sanctioned person stands accused of, while the U.S. issues detailed guidance on how people can contest a sanction.

In its response, the department says it’s already working to boost technical knowledge and processes on sanctions and intends to have the equivalent of 22 full-time staff working solely on sanctions policy.

The department grants exceptions to sanctions called permits. The review notes this includes “Canadians waiting to receive funds from Russia, such as child support, tuition or pension payments, which happen to be sent through sanctioned financial institutions.”

The report also cites media reports about sectoral sanctions against Russia that barred Canadian farmers from importing key fertilizer components.

“Many outstanding permit applications were awaiting a response for hundreds of days,” the report says.

Unlike sanctions imposed by most other countries, or Canadian terrorism designations, Canada’s sanctions include no sunset clause to trigger a review every few years.

Russians and Haitians branded as oligarchs have challenged Canadian sanctions in the courts, accusing Ottawa of running an opaque system that punishes them without Ottawa providing specific claims and evidence.

Former Haitian prime minister Laurent Lamothe has spent nearly three years trying to clear sanctions based on allegations he facilitated gang activity in Haiti, a charge he vehemently denies.

Some prominent lawyers sent a letter to the federal government last month urging it to add resources to reduce the backlog of applications from people seeking to have sanctions lifted.

Global Affairs said “work is already underway to bolster” information posted online about how to comply with sanctions, and the department is looking at having medium-level bureaucrats approve exemptions to sanctions laws.

The department noted Canada’s sanction regime will face more questions as it moves to become the first country to forfeit assets owned by prominent Russians – such as a large cargo plane parked at Toronto’s Pearson airport – to help fund Ukraine’s war effort.

Conservative MP James Bezan said he plans to table a private member’s bill this week that aims to broaden Canada’s sanctions regime to target those behind “breaches of international peace, gross human rights violations and acts of corruption.”

The Tories did not respond to an interview request for Bezan. He is holding a midday press conference today.