1. Title of Resolution:

Transparency and Public Accountability in Canadian Sanctions

2. Estimated cost of implementation to CBA:

(Including the amount of any increase in budget requirements, any potential savings, and the amount of staff time to implement the resolution) Note: National Office staff can assist in calculating implementation cost.

N/A

3. Contact person who can assist the Board of Directors to implement the Resolution:

Name: : Sean Stephenson
Firm name: Dentons Canada LLP
Telephone: (416) 455-2744
E-mail: : sean.stephenson@dentons.com

4.Implementation Calendar

(List steps to be taken by the CBA to implement the Resolution and suggested dates for completion of each step)

Letters to Finance Canada and provincial/territorial Finance Ministers: March/April 2025.

5. Indicator of Success

(The practical result which, if achieved, will show that the Resolution has been successfully implemented by the CBA.)

Direct response from GAC or a commitment to provide guidance

6. Any information not appearing on the face of the Resolution to inform the deliberations:

(Attach or link to any background papers or other documentation in addition to this form which should be submitted to the Annual Meeting with the Resolution. Attach or link to documentation in both French and English, where it exists in both official languages.)

Since 2022, the Section of International Law has actively monitored, discussed, and advocated in the area of economic sanctions. The Section has a dedicated and active sanctions working group of roughly 50 members and has met with Global Affairs Canada on numerous occasions to discuss Canada’s economic sanctions. Notably, since 2022, the Section has consistently called for guidance on Canada’s sanctions regime. The Section has organized itself, and submitted common questions for Global Affairs Canada. Since that time there has been effectively no guidance that is responsive to the Sections’ list of issues.

In addition to guidance, Canadian sanctions practitioners have found that Global Affairs Canada has consistently not responded to sanctions permit applications in a timely manner, has refused to provide reasons for listing individuals and entities, and refused to respond in the statutory deadlines to sanctions delisting applications.

The Section considers it imperative to formally document our request for guidance, responding to sanctions permits, information on the listing of individuals and entities, and responding to delisting applications.

At its heart, the issues raised go to critical elements of a sophisticated legal system- consistency and predictability. Better understanding Canadian sanctions will put Canadians in a better place to comply with them, and will align Canada with our allies.

Some of the Sections actions can be viewed here.

CBA submission on Bill C-47 – Improving the Economic Sanctions Regime – Letter to Senate of Canada.

CBA submission on Bill C-47 – Improving the Economic Sanctions Regime – Letter to House of Commons.

7. (i) Person moving Resolution:

Will be present at Annual Meeting: Yes (virtual) ☒ | No ☐

Name: : Sean Stephenson
Firm name: Dentons Canada LLP
Telephone: (416) 455-2744
E-mail: : sean.stephenson@dentons.com

7. (ii) Person seconding Resolution:

Will be present at Annual Meeting: Yes (virtual) ☒ | No ☐

Name: Ryan Pistorius
Firm name: Gowling WLG (Canada) LLP
Telephone: (613) 786-0083
E-mail: : ryan.pistorius@gowlingwlg.com

7. (iii) Branch, Section, Committee or Subcommittee sponsoring resolution:

International Law

8. Branches, Sections, Committees or Subcommittees directly affected by implementation of this resolution:

International Law, Business Law, Criminal Law, Commodity Tax, Customs and Trade and the Competition Law and Foreign Investment Review Sections