Canadian Sanctions List

Canada maintains an active sanctions regime under multiple legislative instruments, targeting over 5,400 individuals and entities across 18 countries. Uniquely among Western sanctions frameworks, Canada also maintains a Named Research Organizations List that restricts federally funded research partnerships with institutions linked to foreign military and state security entities.

Legislative framework

Canada's sanctions are enacted under several pieces of legislation:

• Special Economic Measures Act (SEMA) — Canada's primary sanctions legislation, allowing the government to impose economic sanctions in response to international crises, gross human rights violations, or threats to international peace and security
• Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) — often called the "Sergei Magnitsky Law," this targets foreign nationals responsible for gross violations of human rights or significant corruption
• United Nations Act — implements UN Security Council sanctions resolutions into Canadian law

The Consolidated Sanctions List

Global Affairs Canada maintains a Consolidated Sanctions List that includes all persons and entities designated under SEMA, JVCFOA, and UN sanctions.[1] Sanctions measures that may apply to listed parties include:

• Asset freezes and prohibitions on making assets available
• Arms restrictions and export controls
• Financial restrictions (prohibitions on financial services)
• Import and export restrictions on specified goods
• Investment bans
• Services bans and transportation restrictions

The list is actively maintained, with regular amendments. In February 2026, Canada amended the Special Economic Measures (Russia) Regulations to add numerous Russian individuals and entities, including major oil companies and financial institutions.[2]

Named Research Organizations List

Canada's Named Research Organizations List is unusual among Western sanctions frameworks. It identifies universities, research institutes, and laboratories connected to military, national defence, or state security entities that pose risks to Canada's national security.[3]

The list currently includes 238 organizations:

• 196 from China — including universities and institutes linked to the People's Liberation Army, the Ministry of State Security, and defence industry conglomerates
• 30 from Iran — research institutions with ties to Iran's military and nuclear programs
• 12 from Russia — institutions connected to Russia's defence and security establishment

Who must comply

• Canadian citizens and permanent residents — regardless of where they are located
• Entities incorporated in Canada — including their activities outside Canada
• Anyone in Canada — regardless of citizenship
• Researchers receiving Canadian federal funding — must screen against the Named Research Organizations List

Multi-jurisdictional considerations

Canadian organisations with US or European operations face overlapping sanctions obligations. Canada's sanctions programs do not always mirror those of the US (OFAC) or the EU. A party sanctioned by Canada may not be sanctioned by the US, and vice versa. Organisations operating across jurisdictions should screen against all applicable lists.

The Named Research Organizations List is particularly important for Canadian universities that also collaborate with US institutions, as US export controls (BIS Entity List) may apply to similar — but not identical — sets of foreign research institutions.