As we reported in November 2017, two new Canadian federal sanctions provisions were adopted that impose monthly reporting obligations on securities firms. On February 22, 2018, the Canadian Securities Administrators (CSA) published Staff Notice 31-352 Monthly Suppression of Terrorism and Canadian Sanctions Reporting Obligations (Notice 31-352), a revised monthly reporting form, and a companion guidance document (STCS Guide). Together, Notice 31-352 and the STCS Guide:
- provide a general overview of Canada’s regulatory measures against terrorist financing and against financial dealings with certain sanctioned individuals; and
- outline the current regulatory requirements (including compliance and reporting obligations) that flow from this regime and apply to registrants, exempt dealers and exempt advisers.
Notice 31-352 states that although CSA staff will strive to ensure the STCS Guide is current and includes all federal provisions requiring monthly STCS reports, it is the responsibility of each registrant, exempt dealer and exempt adviser to comply with the relevant federal regulations at all times. The penalties for doing business with an individual or entity named in any of the federal lists can be severe.