SANCTIONS “DEEMED OWNERSHIP”
UNDER CANADA’S NEW RULES, NAME SCREENING ALONE NOW OBSOLETE?
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For years, many people have attempted to comply with Canada's sanctions rules by simply "name screening". New guidance from Global Affairs Canada ("GAC") may have made that approach obsolete, refocusing compliance on "deemed ownership", including aggregated ownership, board control rights and de facto control (e.g., through contracts and proxies).