Regulations Amending Certain Regulations Made Under the United Nations Act: SOR/2026-180

Canada Gazette, Part II, Volume 160, Number 17

Registration
SOR/2026-180 August 13, 2026

UNITED NATIONS ACT

P.C. 2026-760 August 13, 2026

Whereas the Security Council of the United Nations, acting under Article 41 of the Charter of the United Nations, has adopted certain resolutions;

And whereas it appears to the Governor in Council to be necessary to make regulations in order to enable the measures set out in those resolutions to be effectively applied;

Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending Certain Regulations Made Under the United Nations Act under section 2 of the United Nations Act ^{footnote a}.

Regulations Amending Certain Regulations Made Under the United Nations Act

Regulations Implementing the United Nations Resolutions on the Democratic Republic of the Congo

1 The definitions Committee of the Security Council, designated person and military activities in section 1 of the Regulations Implementing the United Nations Resolutions on the Democratic Republic of the Congo ^{footnote 1} are replaced by the following:

Committee of the Security Council

means the Committee of the Security Council of the United Nations established under paragraph 8 of Resolution 1533 (2004) of March 12, 2004, adopted by the Security Council. (Comité du Conseil de sécurité)

designated person

means a person that is designated by the Committee of the Security Council. (personne désignée)

military activities

means any activities conducted by state armed forces or non-state armed actors and any activities that support their operational capabilities. (activités militaires)

2 Paragraph 2(a) of the Regulations is replaced by the following:

• (a) deal in any property in Canada that is owned — or that is held or controlled, directly or indirectly — by a designated person;

3 The portion of section 2.1 of the French version of the Regulations before paragraph (a) is replaced by the following:

Exception — aide humanitaire

2.1 L’article 2 n’a pas pour effet d’interdire la fourniture, le traitement ou le versement de fonds, d’autres avoirs financiers ou de ressources économiques, ni la fourniture de biens et de services nécessaires à l’acheminement en temps voulu de l’aide humanitaire ou à l’appui d’autres activités visant à répondre aux essentiels en République démocratique du Congo par :

4 Sections 3 to 6 of the Regulations are replaced by the following:

Embargo — arms and related material

3 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly sell, supply or transfer, directly or indirectly, arms and related material, wherever situated, to any person in the Democratic Republic of the Congo.

Embargo — military activities

4 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly provide, directly or indirectly, to any person in the Democratic Republic of the Congo, technical assistance related to military activities.

Embargo — transport

5 It is prohibited for any owner or master of a Canadian vessel, as defined in section 2 of the Canada Shipping Act, 2001, or any operator of an aircraft registered in Canada or any Canadian owner or master of a vessel or any Canadian operator of an aircraft to knowingly carry or cause or permit to be carried arms and related material that are destined for a person in the Democratic Republic of the Congo.

Exception — non-lethal military equipment

6 (1) Sections 3 and 5 do not apply to non-lethal military equipment that is intended solely for humanitarian or protective use or to related technical assistance.

Exception — protective clothing

(2) Sections 3 and 5 do not apply to protective clothing, including flak jackets and military helmets, that is temporarily exported to the Democratic Republic of the Congo by United Nations personnel, representatives of the media, humanitarian and development workers and associated personnel solely for their personal use.

5 Section 8 of the Regulations is repealed.

6 The portion of subsection 14(2) of the Regulations before paragraph (a) is replaced by the following:

Certificate

(2) If it is established in accordance with Resolution 1807 (2008) of March 31, 2008, adopted by the Security Council, or any related resolution adopted subsequently, that the property is necessary for basic or extraordinary expenses or that it is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following time periods:

Regulations Implementing the United Nations Resolutions on Somalia

7 (1) The definitions AMISOM, designated person under paragraph 3, designated person under paragraph 8, military activities and Security Council Resolution 2111 in section 1 of the Regulations Implementing the United Nations Resolutions on Somalia ^{footnote 2} are repealed.

(2) The definition Committee of the Security Council in section 1 of the Regulations is replaced by the following:

Committee of the Security Council

means the Committee of the Security Council of the United Nations established by Resolution 2713 (2023) of December 1, 2023, adopted by the Security Council. (Comité du Conseil de sécurité)

(3) Section 1 of the Regulations is amended by adding the following in alphabetical order:

designated person

means a person that is designated by the Committee of the Security Council. (personne désignée)

8 (1) Paragraph 2(1)(a) of the Regulations is replaced by the following:

• (a) deal in any property in Canada that is owned — or that is held or controlled, directly or indirectly — by a designated person;

(2) Paragraphs 2(1)(d) to (f) of the Regulations are replaced by the following:

• (e) make available any property, other than property referred to in subsection 3(2), to or for the benefit of a designated person or a person acting on behalf of or at the direction of a designated person;
• (f) provide any financial or related services to or for the benefit of any person referred to in paragraph (e) or acquire any such services from or for the benefit of any such person.

(3) The portion of subsection 2(2) before paragraph (b) of the Regulations is replaced by the following:

Payments

(2) Subsection (1) does not prohibit the payment of interest or other earnings to a designated person if

• (a) the payment is the result of a dealing or transaction that occurred before the person became a designated person; and

9 The portion of section 2.1 of the French version of the Regulations before paragraph (a) is replaced by the following:

Exception — aide humanitaire

2.1 L’article 2 n’a pas pour effet d’interdire la fourniture, le traitement ou le versement de fonds, d’autres avoirs financiers ou de ressources économiques, ni la fourniture de biens et de services nécessaires à l’acheminement en temps voulu de l’aide humanitaire ou à l’appui d’autres activités visant à répondre aux essentiels en Somalie par :

10 Subsection 3(2) of the Regulations is repealed.

11 Section 4 of the Regulations is replaced by the following:

Embargo — Security Council Resolution 2776

4 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly sell, supply or transfer, directly or indirectly, to Somalia or to any person in Somalia any of the items listed in Part I of Annex B to Resolution 2776 (2025) of March 3, 2025, adopted by the Security Council or in any related resolution adopted subsequently, or export to Somalia.

12 (1) The portion of section 5 of the Regulations before paragraph (a) is replaced by the following:

Embargo — transport

5 It is prohibited for any owner or master of a Canadian vessel, as defined in section 2 of the Canada Shipping Act, 2001, or any operator of an aircraft registered in Canada, any Canadian owner or master of a vessel or any Canadian operator of an aircraft to knowingly carry or cause or permit to be carried arms and related material, or items referred to in section 4, that are destined for

(2) Paragraph 5(b) of the Regulations is replaced by the following:

• (b) any designated person.

13 Section 7 of the Regulations is replaced by the following:

Exception — non-lethal military equipment

7 (1) Subsection 3(1) and paragraph 5(a) do not apply to non-lethal military equipment that is intended solely for humanitarian or protective use or to related technical assistance.

Exception — protective clothing

(2) Subsection 3(1) and paragraph 5(a) do not apply to protective clothing, including flak jackets and military helmets, that is temporarily exported to Somalia by United Nations personnel, private security contractors, representatives of the media, humanitarian and development workers and associated personnel solely for their personal use.

14 Paragraphs 8(a) to (d) of the Regulations are replaced by the following:

• (a) Somalia;
• (b) the Somali National Army;
• (c) the Somali National Intelligence and Security Agency;
• (d) the Somali National Police Force;
• (e) the Somali Custodial Corps;
• (f) United Nations personnel, including personnel of the United Nations Transitional Assistance Mission in Somalia and the United Nations Support Office in Somalia;
• (g) peacekeeping operations authorized by the African Union and those conducted by the African Union Support and Stabilization Mission in Somalia and its troop- and police-contributing member states;
• (h) training provided by the European Union; or
• (i) training provided by any Member State of the United Nations with a status of forces agreement or a memorandum of understanding with Somalia, if the Member State has notified the Committee of the Security Council that the agreement exists.

15 Section 9 of the Regulations is repealed.

16 Subsection 10(1) of the Regulations is repealed.

17 The portion of section 12 of the Regulations before paragraph (a) is replaced by the following:

Duty to determine

12 The following entities must determine on a continuing basis whether they are in possession or control of property that is owned, held or controlled by or on behalf of a designated person:

18 Paragraph 13(1)(a) of the Regulations is replaced by the following:

• (a) the existence of property in their possession or control that they have reason to believe is owned, held or controlled by or on behalf of a designated person; and

19 (1) The portion of subsection 15(2) of the Regulations before paragraph (a) is replaced by the following:

Certificate

(2) If it is established in accordance with Security Council Resolution 1844, or any related resolution adopted subsequently, that the property is necessary for basic or extraordinary expenses or that it is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following time periods:

(2) Subparagraph 15(2)(c)(i) of the Regulations is replaced by the following:

• (i) was created or issued before the person became a designated person,

20 (1) Subsection 16(1) of the Regulations is replaced by the following:

Mistaken identity

16 (1) A person whose name is the same as or similar to the name of a designated person and that claims not to be that designated person may apply to the Minister in writing for a certificate stating that they are not that designated person.

(2) Paragraph 16(2)(a) of the Regulations is replaced by the following:

• (a) issue the certificate, if it is established that the applicant is not the designated person; or

Regulations Implementing the United Nations Resolutions on the Central African Republic

21 (1) The definitions armed mercenary and MINUSCA in section 1 of the Regulations Implementing the United Nations Resolutions on the Central African Republic ^{footnote 3} are repealed.

(2) The definitions Committee of the Security Council, designated person and military activities in section 1 of the Regulations are replaced by the following:

Committee of the Security Council

means the Committee of the Security Council of the United Nations established by Resolution 2745 (2024) of July 30, 2024, adopted by the Security Council. (Comité du Conseil de sécurité)

designated person

means a person that is designated by the Committee of the Security Council. (personne désignée)

military activities

means any activities conducted by state armed forces or non-state armed actors and any activities that support their operational capabilities. (activités militaires)

22 Paragraph 2(1)(a) of the Regulations is replaced by the following:

• (a) deal in any property in Canada that is owned — or that is held or controlled, directly or indirectly — by a designated person;

23 Paragraphs 3(a) and (b) of the Regulations are replaced by the following:

• (a) sell, supply or transfer, directly or indirectly, arms and related material, wherever situated, to any non-state armed actors in the Central African Republic; or
• (b) provide, directly or indirectly, technical assistance or financial assistance related to the sale, supply, transfer, manufacture, maintenance or use of arms and related material to any non-state armed actors in the Central African Republic.

24 Sections 4 to 9 of the Regulations are replaced by the following:

Embargo — military activities

4 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly provide, directly or indirectly, to any non-state armed actors in the Central African Republic, technical or financial assistance related to military activities.

Embargo — transport

5 It is prohibited for any owner or master of a Canadian vessel, as defined in section 2 of the Canada Shipping Act, 2001, or any operator of an aircraft registered in Canada or any Canadian owner or master of a vessel or any Canadian operator of an aircraft to knowingly carry or cause or permit to be carried, arms and related material that are destined for any non-state armed actors in the Central African Republic.

25 Subsection 13(2) of the Regulations is replaced by the following:

Certificate

(2) The Minister must issue the certificate if the Security Council did not intend that the activity be prohibited.

26 The portion of subsection 14(2) of the Regulations before paragraph (a) is replaced by the following:

Certificate

(2) If it is established in accordance with Resolution 2399 (2018) of January 30, 2018, adopted by the Security Council, or any related resolution adopted subsequently, that the property is necessary for basic or extraordinary expenses or that it is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following time periods:

Regulations Implementing the United Nations Resolutions on South Sudan

27 (1) The definitions designated persons and military activities in section 1 of the Regulations Implementing the United Nations Resolutions on South Sudan ^{footnote 4} are replaced by the following:

designated person

means a person that is designated by the Committee of the Security Council. (personne désignée)

military activities

means any activities conducted by state armed forces or non-state armed actors and any activities that support their operational capabilities. (activités militaires)

(2) The definition Comité du Conseil de sécurité in section 1 of the French version of the Regulations is replaced by the following:

Comité du Conseil de sécurité

Comité du Conseil de sécurité des Nations Unies créé en application du paragraphe 16 de la résolution 2206 (2015) du 3 mars 2015 adoptée par le Conseil de sécurité. (Committee of the Security Council)

28 Paragraph 2(a) of the Regulations is replaced by the following:

• (a) deal in any property in Canada that is owned — or that is held or controlled, directly or indirectly — by a designated person;

29 Section 3 of the Regulations is amended by striking out “or” at the end of paragraph (a), by adding “or” at the end of paragraph (b) and by adding the following after paragraph (b):

• (c) provide, directly or indirectly, to South Sudan or to any person in South Sudan, technical or financial assistance related to the provision of armed mercenaries.

30 Section 4 of the Regulations is replaced by the following:

Embargo — military activities

4 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly provide, directly or indirectly, to South Sudan or to any person in South Sudan technical or financial assistance related to military activities.

31 Subsection 6(1) of the Regulations is replaced by the following:

Exception — non-lethal military equipment

6 (1) Sections 3 and 5 do not apply to non-lethal military equipment that is intended solely for humanitarian or protective use or to related technical assistance.

32 Subsection 7(2) of the Regulations is replaced by the following:

Exception — various entities

(2) If the Committee of the Security Council has been notified in advance, sections 3 and 5 do not apply to an activity that is intended solely for the support of the forces of a state that is taking action, in accordance with international law, to protect or evacuate its nationals and the individuals for whom it has consular responsibility.

33 The portion of subsection 12(2) of the Regulations before paragraph (a) is replaced by the following:

Certificate

(2) If it is established in accordance with Resolution 2206 (2015) of March 3, 2015, adopted by the Security Council, or any related resolution adopted subsequently, that the property is necessary for basic or extraordinary expenses or that it is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following time periods:

Coming into Force

34 These Regulations come into force on the day on which they are registered.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

As a member state of the United Nations (UN), and pursuant to article 25 of the Charter of the United Nations (the UN Charter), Canada is legally obligated to implement binding decisions of the United Nations Security Council (UNSC) taken under Chapter VII of the UN Charter (i.e. decisions and actions with respect to threats to the peace, breaches of the peace, and acts of aggression). These decisions include measures other than the use of force (e.g. sanctions, arms embargoes) to maintain or restore international peace and security where a threat to the peace, breach of the peace, or act of aggression exists.

Recently adopted UNSC resolutions introduced changes to UN sanctions regimes related to the Central African Republic (CAR), the Democratic Republic of the Congo (DRC), South Sudan and Somalia. As a result, Canada is amending United Nations Act (UNA) regulations pertaining to these countries to implement these UNSC decisions into domestic law.

Background

Central African Republic

Following the outbreak of renewed conflict in 2013 in the CAR, the UNSC imposed a broad territorial arms embargo on the country. Associated resolutions adopted in 2014 that imposed a travel ban and asset freeze on individuals and entities undermining peace, violating human rights, or fuelling the conflict were implemented in Canadian law via the Regulations Implementing the United Nations Resolutions on the Central African Republic (the CAR Regulations).

Since the CAR Regulations were last updated, UNSC resolutions 2745 (2024) and 2789 (2025) were adopted. These resolutions introduced changes to the UN sanctions regime, reflecting the UNSC’s commitment to the CAR’s stability and recognition that non-state actors operating in the CAR continue to constitute a threat to peace and security in the region.

Democratic Republic of the Congo

In response to continuing hostilities in the eastern part of the DRC, the UNSC imposed a broad territorial arms embargo against the DRC in July 2003. In 2008, the UNSC amended the arms embargo to no longer apply to the Government of the DRC and, instead, it specifically targeted non-governmental entities and individuals operating in the DRC and requested that all UN member states notify the Committee of the Security Council of any shipment of arms related to the DRC. These measures were implemented in Canadian law via the Regulations Implementing the United Nations Resolutions on the Democratic Republic of the Congo (the DRC Regulations).

Since the DRC Regulations were last updated, UNSC resolutions 2667 (2022) and, more recently, 2783 (2025), were adopted. These resolutions introduced changes to the UN sanctions regime, reflecting the UNSC’s intent to preserve the sanctions framework as a tool to constrain armed group activity and contribute to peace and stability in eastern DRC.

South Sudan

Due to the deteriorating security and humanitarian situation in South Sudan, the UNSC imposed a comprehensive arms embargo on the country in July 2018. In 2022, the UNSC added an exception with regards to the export, sale and transfer of permissible, non-lethal military equipment to support the implementation of the 2018 peace agreement in South Sudan. At this time, the UNSC also introduced the requirement to notify the Committee of the UNSC in advance of supplying permitted non-lethal military equipment to South Sudan. These measures were implemented in Canadian law via the Regulations Implementing the United Nations Resolutions on South Sudan (the South Sudan Regulations).

Since the South Sudan Regulations were last updated, UNSC resolutions 2683 (2023) and recently 2781 (2025) were adopted. These resolutions introduced changes to the UN sanctions regime and continue to support the South Sudan Peace Agreement, as the actors supporting the 2018 peace agreement continue to play a critical role in promoting peace and stability in South Sudan and the broader region.

Somalia

In January 1992, the UNSC imposed a comprehensive arms embargo against Somalia in response to the collapse of the central government and the ensuing civil war marked by widespread factional fighting. Over time, the UNSC refined the regime: amendments in 2007 allowed arms supplies to Somali Government Forces under certain conditions and, in 2008 and 2012, further strengthened measures to address piracy and armed robbery at sea against vessels off the coast of Somalia. These measures were implemented in Canadian law via the Regulations Implementing the United Nations Resolutions on Somalia (the Somalia Regulations).

Since the Somalia Regulations were last updated, UNSC resolutions 2662 (2022), 2713 (2023), 2714 (2023) and, more recently, 2776 (2025) were adopted. These resolutions introduced changes to the UN sanctions regime and reaffirm that all UN member states must prevent deliveries of weapons, ammunition and military equipment to Al-Shabaab and other designated actors.

Miscellaneous amendments

Following a detailed review of the regulations, the four regulations are being amended to avoid interpretative issues, to ensure consistency across regulations, to reduce redundancy and to reflect the original intent of the UNSC resolutions across these regulations.

Objective

These amendments to the CAR, DRC, South Sudan and Somalia Regulations aim to fulfill Canada’s international legal obligation to implement the binding decisions of the UNSC set out in resolutions 2789 (2025), 2783 (2025), 2781 (2025) and 2776 (2025). Implementing the latest UNSC resolutions from 2025 will capture the amendments and updates made by previous resolutions.

Description

Central African Republic

To implement UNSC Resolution 2789 (2025), the CAR Regulations are amended to remove the arms embargo on the CAR government and to prohibit the direct or indirect supply, sale or transfer of arms and related material specifically to armed groups and associated individuals operating in the CAR, including prohibiting technical, training, financial or other assistance, related to military activities or the provision, maintenance or use of any arms and related material. The UNSC measures also narrow the definition of “armed groups” and, therefore, the amendments remove the reference to “armed mercenaries” across the CAR Regulations. Amendments are made as follows:

• Repeal the definition of “armed mercenary” and MINUSCA, and other mentions of these terms across the Regulations.
• Update the definition of “military activities” to replace the concept of “non-state armed forces” by “non-state armed actors.”
• Update the arms embargo to capture all non-state armed actors and remove the embargo on the Government of the CAR.
• Remove the requirement for advance approval or advance notification to the Committee of the Security Council for any activities permitted via exceptions.

Democratic Republic of the Congo

To implement UNSC Resolution 2783 (2025), the DRC Regulations are amended to remove the notification requirement to the Committee of the Security Council of any shipment of arms and related material to the DRC, or any provision of assistance, advice or training related to military activities in the DRC. It also removes the notification requirement to the Committee of the Security Council in advance of any UN member state providing non-lethal military equipment intended solely for humanitarian or protective use, and related technical assistance and training. Amendments are made as follows:

• Update the definition of “military activities” to remove the mention of “armed mercenaries” and “non-state armed forces” and replace them with “non-state armed actors.”
• Remove the requirement of advance notification of the Committee of the Security Council in the case of (1) other supplies of non-lethal military equipment intended solely for humanitarian or protective use, and related technical assistance and training; and (2) in the case of an activity that is intended solely for the support of the DRC in managing their security challenges.

South Sudan

To implement UNSC Resolution 2781 (2025), the South Sudan Regulations are amended to remove the notification requirement to the Committee of the Security Council in advance of any UN member state supplying, selling or transferring non-lethal military equipment and related technical assistance or training, when provided in support of the implementation of the terms of the 2018 peace agreement. Further, the South Sudan Regulations are amended to remove the reference to the African Union Regional Task Force, as it was dissolved in 2018. Amendments are made as follows:

• Update the definition of “military activities” to remove the mention of “armed mercenaries” and “non-state armed forces” and replace them with “non-state armed actors.”
• Update the embargo on military activities to remove the mention of “armed mercenary personnel.”
• Update the exception regarding non-lethal military equipment to include related technical assistance intended solely for humanitarian or protective use if the Committee of the Security Council has been notified in advance of its intended use.
• Update the exception related to non-lethal military equipment to reflect the removal of the advance-notification requirement to the Security Council Committee when the equipment is intended solely to support the implementation of the terms of the peace agreement (the June 27, 2018, Khartoum Declaration).

Somalia

To implement UNSC Resolution 2776 (2025), the Somalia Regulations are amended to reflect the exemptions to the arms embargo and related materials, which permit the supply of arms and related material to Somali Government Forces, UN personnel and other authorized Somali security institutions specifically exempted by the Council. Further, the amendments include a new prohibition on the export of explosive precursors and materials that may be used in the manufacture of improvised explosive devices (IEDs) and update the list of banned components, which can be found in Part I of Annex B of UNSC Resolution 2776 (2025) [PDF]. The amendments also remove the exception regarding non-lethal military equipment by removing the requirement for advance notice to the Committee of the Security Council. Further, the Somalia Regulations are amended to remove the reference to the African Union Mission in Somalia (AMISOM). Amendments are made as follows:

• Repeal the definitions of the “African Union Mission to Somalia (AMISOM),” “Security Council Resolution 2111” and “military activities,” and other mentions of these terms across the Regulations.
• Update the arms embargo to capture all non-state armed actors and include an exception in support of the Somali Government Forces, UN personnel, and other Somali security institutions expressly exempted under Security Council resolutions.
• Include an export prohibition on the export of explosive precursors and materials that may be used in the manufacture of improvised explosive devices, consistent with Part I of Annex B of Resolution 2776 (2025).
• Remove the requirement for advance notice to the Committee of the Security Council, in the case of non-lethal military equipment.
• Update the exception regarding protective clothing to extend its application to private security contractors operating in Somalia.

Miscellaneous amendments

In addition to making translation and small editorial amendments to ensure clarity and reflect the original intent of the UNSC resolutions, these regulations are amended as follows:

• Update the “designated person” and “Committee of the Security Council” definitions, as well as the provision related to the application of certificates to reference the relevant UNSC resolutions and provide ambulatory language to capture all future UNSC amendments.
• Update the dealings prohibitions in the regulations to remove references to persons acting on behalf of, or at the direction of a designated person, to reflect language consistency with Canada’s bijural legal system.

Regulatory development

Consultation

Global Affairs Canada (the Department) regularly engages with relevant stakeholders, including civil society organizations, other like-minded governments and international forums, regarding Canada’s approach towards sanctions implementation.

As a member of the UN, Canada is obliged to implement the measures included in UNSC resolutions pursuant to Chapter VII of the UN Charter. With respect to the amendments, no external outreach was conducted.

Indigenous engagement, consultation and modern treaty obligations

In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an analysis was undertaken to determine whether the amendments are likely to give rise to modern treaty obligations. The assessment examined the geographic scope and subject matter of the amendments in relation to modern treaties in effect, and no modern treaty obligations were identified.

Instrument choice

The imposition of sanctions against foreign states and non-state actors is a key tool for the international community to support peace and security and enforce international norms and laws. The Parliament of Canada has enacted legislation authorizing the imposition of sanctions through the United Nations Act (UNA), the Special Economic Measures Act and the Justice for Victims of Corrupt Foreign Officials Act.

Sanctions measures under the UNA are imposed by the Governor in Council, on the recommendation of the Minister of Foreign Affairs, through a regulatory process. Regulations are the sole method to enact UNSC resolutions related to sanctions in Canada. This is the preferred instrument to be considered.

Regulatory analysis

Benefits and costs

With these amendments, Canada will be brought into compliance with its obligations under the UN Charter by implementing the measures outlined in UNSC resolutions 2789 (2025), 2783 (2025), 2781 (2025) and 2776 (2025).

The amendments lift the requirement to seek advance approval and/or provide advance notification to the Committee of the Security Council ahead of undertaking certain activities with most of these countries, which removes an administrative barrier for businesses wishing to undertake those activities. Nonetheless, commercial relations between Canada and the CAR, DRC, South Sudan and Somalia are limited:

• Canadian exports to the CAR in 2025: $3.1 million (mainly items categorized as motor cars and other mid-size passenger vehicles, valves used in plumbing, heating, and hydraulic systems, and pumps).
• Canadian exports to the DRC in 2025: $21.4 million (mainly items categorized as motor cars and other mid-size passenger vehicles, and machinery used to process mineral substances).
• Canadian exports to South Sudan in 2025: $374,642 (primarily items categorized as vegetables and legumes).
• Canadian exports to Somalia in 2025: $3.0 million (primarily items categorized as transmission apparatus for radio/television and cameras, aerospace products, and machinery).

Therefore, the impacts of the proposed amendments on Canadian businesses are anticipated to be minor.

The amendments to the Somalia Regulations introduce new prohibitions on explosive precursors and materials that may be used in the manufacture of IEDs, which could create additional costs for Canadian businesses seeking certificates that would authorize them to carry out specified activities or transactions that are otherwise prohibited. Please refer to Annex B of UNSC Resolution 2776 (2025) [PDF] for a full list of items under this category. The export of explosives prohibited by the Somalia Regulations is already controlled under Canada’s Explosives Act, meaning that a permit is currently required if they were to be exported. However, in the past two years, there have been no applications to export those controlled substances to Somalia. The amendments would also create costs for the Government of Canada for administering and enforcing these additional prohibitions. However, Global Affairs Canada does not anticipate any applications resulting from these amendments, as the Department’s assessment has not identified business dealings within the newly prohibited items under that category.

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions will be minimal. Given that the Canadian Border Services Agency (CBSA) currently enforces prohibitions and controls related to exports of goods from Canada to Somalia under the Somalia Regulations, the Export Control List and the Explosives Act, the incremental resource impacts on the CBSA are not expected to be significant.

Small business lens

The amendments would create additional costs for small businesses that seek certificates authorizing them to carry out specified activities or transactions that are otherwise prohibited. However, it is unlikely that Canadian small businesses will seek to export explosive precursors and materials that may be used in the manufacture of improvised explosive devices that would be prohibited by the amended UN Somalia Regulations. No significant loss of opportunities for small businesses is expected as a result of the amendments.

To facilitate compliance by small businesses, Global Affairs Canada conducts enhanced outreach with stakeholders to better inform them of changes to Canada’s sanctions. This includes updates to the sanction’s website.

One-for-one rule

The certificate process falls within the definition of administrative burden under the Red Tape Reduction Act. However, based on historical data, no certificate applications are anticipated, there is no incremental change in administrative burden on businesses, and no regulatory titles are repealed or introduced.

Regulatory cooperation and alignment

While the amendments are not related to a work plan or commitment under a formal regulatory cooperation forum, they align with UNSC resolutions 2789 (2025), 2783 (2025), 2781 (2025) and 2776 (2025), and are made to fulfill Canada’s obligation to implement all measures taken by the UNSC under the UN Charter.

International obligations

Compliance with Canada’s international commitments was considered in the development of these amendments.

Effects on the environment

The amendments are unlikely to result in important environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment, a preliminary scan concluded that a strategic environmental and economic assessment is not required.

Gender-based analysis plus

The subject of sanctions has previously been addressed for effects on gender and diversity. Although sanctions are intended to facilitate change to restore peace and security, protect and advance human rights, and combat foreign corruption through economic pressure on states and responsible individuals, they can nevertheless have an impact on vulnerable groups and individuals. In countries facing sanctions, such groups have historically been more likely to bear the political and economic instability caused by economic sanctions due to their disadvantaged position in society.

Implementation, compliance and enforcement, and service standards

The amendments come into force on the day they are registered.

The Sanctions Bureau of Global Affairs Canada administers applications for permits and certificates. Such applications would allow the export of items under Canada’s sanctions regulations, namely regulations under the Special Economic Measures Act, the UNA and the Justice for Victims of Corrupted Foreign Officials Act. Certificates may be granted in exceptional circumstances on a case-by-case basis and at the discretion of the Minister of Foreign Affairs. The Minister must issue a certificate if the Security Council did not intend that an activity be prohibited, or if the Security Council has approved the activity in advance.

The Trade Commissioner Service at Global Affairs Canada, abroad and in Canada, continues to assist clients in understanding Canadian sanctions regulations, and notably the impact of the regulations on any activities in which Canadians may be engaged. Global Affairs Canada and enforcement partners are also increasing outreach efforts across Canada — including to engage with businesses, universities and provincial/territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

Canada’s sanctions regulations are enforced by the Royal Canadian Mounted Police (RCMP) and the CBSA. In accordance with section 3 of the UNA, every person who knowingly contravenes or fails to comply with the regulations is liable, upon summary conviction, to a fine of not more than $100,000 or to imprisonment for a term of not more than one year, or to both and, upon conviction on indictment, to imprisonment for a term of not more than 10 years.

Global Affairs Canada collaborates with CBSA for effective enforcement, activating a border lookout for imports when a new prohibition is implemented and providing assessments on whether sanctions are engaged, as requested. For exports, CBSA conducts research and identifies possible targets on domestic and international trade chain partners. CBSA also possesses the essential on-the-ground presence, expertise and authorities for enforcement.

Contact

Sanctions Bureau
Global Affairs Canada
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Email: sanctions@international.gc.ca