On December 16, 2011, the Governor-in-Council issued amendments to the Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations under the Freezing Assets of Corrupt Foreign Officials Act. The modifications provide an amended and updated list of persons from Egypt and Tunisia subject to asset freezing measures.
Freezing and Disclosure Obligations
All individuals and entities in Canada should be aware of the prohibition to conduct the following activities with corrupt foreign officials from Egypt or TunisiaFootnote 1:
- to deal, directly or indirectly, in any property, wherever situated, of a listed politically exposed foreign person;
- to enter into or facilitate, directly or indirectly, any financial transaction related to a dealing referred to in the previous point;
- to provide financial services or other related services in respect of any property of a listed politically exposed foreign person.
In addition, all individuals and entities in Canada, as well as every Canadian outside Canada, must advise the Commissioner of the Royal Canadian Mounted Police if they have property of any of these foreign officials in their possession or under their control.Footnote 2
In accordance with these regulations, a corrupt foreign official is one that is named in the Freezing Assets of Corrupt Foreign Officials (Tunisia and Egypt) Regulations. The names of corrupt foreign officials are included in those Regulations, as follows:
- Names in Schedule 1 and Schedule 2 (called “politically exposed foreign persons”) effective March 23, 2011 (http://www.gazette.gc.ca/rp-pr/p2/2011/2011-04-13/html/sor-dors78-eng.html)
- Corrections to the names included in Schedule 1 and Schedule 2 in March, as well as additional names effective December 16, 2011 http://www.international.gc.ca/sanctions/tunisia_egypt_developments-developpements_tunisie_egypte.aspx?view=d
For more information on all measures relating to corrupt foreign officials, consult the Foreign Affairs and International Trade website: (http://www.international.gc.ca/sanctions/tunisia_egypt-tunisie_egypte.aspx?lang=eng&view=d)
For more information on FINTRAC Advisories in relation to Egypt and Tunisia, please consult the following link:
The Office of the Superintendent of Financial Institutions (OSFI) has also issued a Notice to all federally regulated financial institutions. For a copy of the Notice, visit: