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Canadian Sanctions Delisting Process 'Unclear,' Law Firm Says

The process for removing names from Canadian sanctions lists lacks transparency, Dentons said in a June client alert. The firm said Global Affairs Canada doesn’t “provide any material or information providing support for the decision to list an individual or entity,” and so when a person or entity seeks a delisting, the party has “no access to the reasons” Canada “relied on in including the person or entity on a sanctions list.”

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“This complicates any challenge to the listing -- it is, obviously, difficult to challenge a decision when it is impossible to know why it was taken,” Dentons said, calling the process “unclear and opaque.”

The alert details two recent cases in which people applied to be delisted from Canadian sanctions regimes. The former prime minister of Haiti challenged his designation in a Canadian Federal Court in December, Dentons said, and Russian Formula 1 driver Dmitry Mazepin last year applied for a “judicial review of his listing” under Canada’s Russian sanctions regulations.