Your Guide toSanctions Screeningin Canada

Sanctions can change who you're allowed to do business with overnight. A new restriction can affect a customer, supplier or investor you already know and trust.

This guide explains sanctions screening in Canada, from choosing who to check and which lists to search to reviewing possible matches. It also covers reporting, recordkeeping and when to screen again.

Disclaimer: This guide is a practical overview, not legal advice. Consult current official sanctions guidance, reporting guidance and applicable legislation, and seek qualified legal counsel for your circumstances.

1. What are sanctions, and who needs to screen?

Sanctions are legal restrictions on trade, services or access to money. Governments use them in response to armed conflict, terrorism, corruption and serious human rights abuses. A sanctions list names people and organizations targeted by particular restrictions. Canada applies United Nations sanctions and makes its own sanctions rules. The government adds names to those rules for reasons such as involvement in these activities or support for those responsible.¹

Who do the rules cover?

Canadian sanctions apply to people and businesses in Canada and Canadians abroad. That includes banks and fintechs, but also manufacturers, retailers and service businesses. Sanctions screening compares people and businesses against sanctions lists to identify possible restrictions. The rules depend on your dealings; no single screening process applies to every Canadian business.¹

Banks, money services businesses and other reporting entities have additional duties under Canada's anti-money-laundering rules. These include ongoing monitoring and reporting to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

Who should you check?

Start with the person or business you're dealing with. For a company, identify its owners and who can direct its decisions. Collect enough detail to tell them apart from others with similar names:

• People: full name, other names they use, date of birth and address.

• Businesses: registered name, registration number, country of registration and ownership records, including companies between the business and its ultimate owners.

If a contract only says “Bayside Trading,” ask for the registered name and number. An ownership chart or shareholder register can help you identify who else to check.

What can happen if you get it wrong?

In Canada, a wilful breach of sanctions rules under the Special Economic Measures Act can carry up to five years in prison. Recent U.S. sanctions cases show the financial consequences and the failures behind them:⁶

• GVA Capital: US$215.99 million penalty in 2025. The investment firm knowingly managed a listed person's investment through his nephew. The penalty also covered failing to answer a formal request for information.

• Bank of America: US$11.66 million settlement in October 2026. Failures included outdated screening lists and too little priority for alerts with exact name and birth-date matches.

• IMG Academy: US$1.72 million settlement in 2026. The Florida school contracted with two listed parents without screening them, and accepted tuition payments, including through other people.⁶

2. How do you search sanctions lists?

Check these six Canadian sanctions and asset-freezing regimes separately:

Regime	Where to check
UN Security Council sanctions: implemented under Canada's United Nations Act	UN consolidated list and Canada's implementing regulations.
SEMA: Special Economic Measures Act	Canadian Autonomous Sanctions List, for SEMA entries.
Magnitsky / JVCFOA: Justice for Victims of Corrupt Foreign Officials Act	Canadian Autonomous Sanctions List, for JVCFOA entries.
Criminal Code listed terrorist entities	Public Safety Canada's list.
RIUNRST: Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism	The separate schedule to these regulations.
FACFOA: Freezing Assets of Corrupt Foreign Officials Act	Tunisia regulations, Schedule 1. The Ukraine FACFOA regulations expired on March 6, 2024.

The Canadian Autonomous Sanctions List covers SEMA and JVCFOA only. It can lag legal changes; check the current regulations.

Search and review results

Checking manually: Search names, aliases and spelling variations across these sources. Repeat for relevant owners and others involved. Save the results and sources. Multiple lists and repeat checks make this time-consuming.

Using screening software: Search individual records or your whole customer list against enabled lists. Alerts should show the source and identifying details. Match scores help prioritize review.

On the Canadian Autonomous Sanctions List, Regulation names the rules; Schedule identifies the list within them. Use Canada's sanctions page to open the regulation and check restrictions for that schedule. Country, product or service restrictions can apply without a name match.¹

What if you do business abroad?

Canada's lists are only part of the picture. Map where your business and the people you deal with operate, what goods or services are involved and how any payments will travel. Then confirm which countries' rules apply and include their lists in your checks:

• United States: A payment passing through a U.S. bank can bring U.S. sanctions into the review. Check the U.S. Treasury's Office of Foreign Assets Control (OFAC) lists.

• United Kingdom or European Union: Operations or business conducted there can require checks against the UK Sanctions List or EU sanctions, alongside Canadian rules.⁷

If you rely on another bank, payment provider or screening vendor, confirm which lists it covers. Check for conflicts between Canadian and foreign rules with counsel. For example, Canadian law prohibits Canadian companies from following certain U.S. restrictions on trade between Canada and Cuba.⁷

3. What should you do with a possible match?

A similar name can trigger an alert for the wrong person.

Example: reviewing a name match

1

Compare the alert

Sample customerAlexei Miller

OFAC aliasAlexei Borisovich Miller

1962 birth yearRussia birth countryPossible match

2

Compare verified identity details

Verified passport OFAC record

Full name

Customer

Alexei Andreevich Miller

OFAC

Alexey Borisovich Miller

Birth date

Customer

13 January 1962

OFAC

31 January 1962

Birthplace

Customer

Perm, Russia

OFAC

Saint-Petersburg, Russia

3

Record your decision

Reviewer’s note

False match. “I verified the full name, birth date and birthplace. This is a different person.”

Save screenshots and identity evidence with your reason, name and date.

Why check the owners behind a company?

A listed person can use a company to receive money or services even when the company's name never appears on a list. Checking who owns and controls it helps you spot that connection.

Follow the ownership chain and find out who can direct the business. Under Canada's Special Economic Measures Act, control includes at least 50% of shares, ownership interests or voting rights, directly or indirectly. The power to change the board or direct the company's activities can also count.²

Example: two listed people own 30% and 25% of your customer. Global Affairs Canada's guidance says to consider their combined holdings: 55%. Check how the restrictions affect your dealings with the company. A holding below 50% still needs review if the person controls the business in another way.

A listed owner transfers shares but keeps control

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If someone opens an account on another person's or company's behalf, identify who they represent. For a transaction, consider the recipient and any banks involved. The aim is to understand who directs the activity and who benefits from it.²

4. What if the match looks real?

Pause the proposed transaction or service and send the case to the person responsible for sanctions decisions. Give them the customer details, the listed record, your evidence and what the customer wants to do. If you don't have that expertise in-house, get qualified legal advice. Don't automatically return money: sending it back can also be prohibited.

If the activity is prohibited, it can proceed only under an applicable exception or valid authorization.³

A name alert alone doesn't trigger every reporting duty. What matters is what you know or suspect, whether you hold property such as money in an account, and which rules cover your business. The Royal Canadian Mounted Police (RCMP) and Canadian Security Intelligence Service (CSIS) handle property disclosures:

What have you found?	Who do you tell?
You have reason to believe money or property you hold or control belongs to, is controlled by, or is held for a listed person.	Many sanctions regulations require you to tell the RCMP without delay. Some also allow CSIS. Check the rule covering that listing; this duty can apply even if you don't report to FINTRAC.
You know you hold property owned or controlled by or for a terrorist group.	Tell the RCMP or CSIS without delay, even if the group isn't listed.
You report to FINTRAC and must make a property disclosure covered by its guidance.	Also send FINTRAC a Listed Person or Entity Property Report immediately. No transaction is needed. Use its paper form and fax or mail instructions.
You report to FINTRAC and have reasonable grounds to suspect a completed or attempted transaction involves money laundering, terrorist financing or sanctions evasion.	Send a Suspicious Transaction Report as soon as practicable after establishing those grounds. Use FINTRAC Web Reporting or your organization's existing reporting system. You don't need proof of a crime.

For RCMP sanctions disclosures, use sanctions_intake-triage@rcmp-grc.gc.ca, as listed in its official reporting instructions. If reporting to CSIS, use its official contact details. Include related or proposed transactions in property disclosures. Police or intelligence disclosure and FINTRAC reporting are separate steps; both can apply.³

5. What should you save?

Keep the search date, sources, results, supporting evidence and the reviewer's decision together. Another reviewer should understand the decision without repeating the investigation.

Minerva keeps screening results, decisions, comments and activity history with the customer profile. Record supporting facts there, without recreating the review in a separate spreadsheet. You can also export findings as a PDF report.⁴

Follow your recordkeeping and privacy rules when saving documents. Copies of FINTRAC property reports and Suspicious Transaction Reports must be kept for at least five years after you send them.³

6. When should you screen again?

A customer checked last month could be listed today. For FINTRAC reporting entities, ongoing monitoring is required once a business relationship is established under its rules. Review activity, keep customer and ownership information current, and reassess risk. Set the frequency according to risk, with enhanced monitoring for high-risk relationships. Your policies should specify that frequency; the monitoring requirement isn't a universal daily sanctions-screening rule.⁵

Build rescreening into that process and respond to changes:

What changed?	What to check next
A new listing or restriction	Recheck affected customers and their owners; check whether planned payments or services are still allowed.
A new company owner	Get the updated ownership records, screen the new owners and check who controls the business.
Corrected customer details	Rerun the search with the new name, birth date or other corrected information.
A new supplier, recipient or country	Check new parties and any restrictions on the activity before proceeding.
New facts about an alert you dismissed	Reopen it if those facts undermine your original reason for dismissing it.

Some businesses have continuing legal duties. For example, Canada's Russia regulations require banks and credit unions to check on a continuing basis whether they hold or control property owned or controlled by or on behalf of a Schedule 1 listed person.⁵

Ask your provider two questions: how quickly does it add a new listing, and when does it rerun your customers against that change? Minerva shows a profile's Last Screened time; repeat checks follow your configured monitoring schedule.⁴

7. How do you choose screening software?

Give providers the same test cases: known listed people and companies, unrelated people with similar names, and records with missing details or different spellings. Use examples that resemble your customers.

Measure both true positives (correct matches) and false positives (alerts about unrelated people). Also count listed people the tool misses.

Example: your test contains 20 listed people. Tool A finds all 20 and flags 80 unrelated people. Tool B finds 15 and flags 10 unrelated people. Tool B creates less review work but misses five listed people. Compare detection, unnecessary alerts and review time together, using the same test cases and settings you plan to use.

Check list coverage, ownership information and how quickly changes trigger another check. Repeat your tests after changing settings or sources. Minerva's Calibration workspace lets teams test matching settings before applying them to live screening.⁴

Sources

1. Global Affairs Canada: essential information and search advice, Canadian list and limitations, listing decisions. FINTRAC: sanctioned and terrorist persons and entities.
2. Special Economic Measures Act, section 2.1. Global Affairs Canada: deemed ownership, indirect dealings.
3. Global Affairs Canada: dealings prohibitions. FINTRAC: property reports, sanctions evasion. Criminal Code, section 83.1; reporting regulations, sections 9, 10 and 12.1.
4. Minerva: report exports, case management and saved decisions, sanctions reports, screening and monitoring, match scoring and Calibration.
5. FINTRAC: ongoing monitoring requirements. Global Affairs Canada: compliance guidance. Russia regulations, section 6.
6. Special Economic Measures Act, section 8. U.S. Treasury, Office of Foreign Assets Control: GVA Capital penalty, Bank of America settlement, IMG Academy settlement.
7. U.S. Treasury: obligations of foreign businesses; UK sanctions scope; EU sanctions overview; Canada's blocking order, section 5.