Following the adoption of two new federal regulations relating to the suppression of terrorism or economic sanctions, the Canadian Securities Administrators (CSA) have announced that they are preparing revised guidance to update Staff Notice 31-317 (Revised) Reporting Obligations Related to Terrorist Financing. Registered dealers and advisers, and firms relying on exemptions from the dealer and adviser registration requirements, are advised that they should review the list of listed persons and foreign nationals, as applicable, in the following new federal regulations when completing their monthly reporting obligations despite the fact that such provisions are not currently listed in the Staff Notice:
- Special Economic Measures (Venezuela) Regulations (in force on September 22, 2017). “Listed persons” with whom Canadians and persons in Canada may not deal financially can be found here.
- Justice for Victims of Corrupt Foreign Officials Regulations (in force on November 3, 2017). “Foreign nationals” with whom Canadians and persons in Canada may not deal financially can be found here.
The CSA invite firms to refile “nil” reports filed for September and October 2017 to the extent that such reports need to be changed following review of the applicable lists of listed persons and foreign nationals.