Posted by on Jun 1, 2023

Concerned by the Government of Canada’s recently proposed amendments to the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) (Magnitsky Act) in Bill C-47, the Budget Implementation Act 2023, No. 1 (Bill C-47),[1] the International Law Section of the Canadian Bar Association (CBA Section) has filed a submission with the Parliamentary Standing Committee on Finance.[2]  Bill C-47 is intended to make consequential amendments with respect to commitments made by the Government in its 2023 Budget.

Michael Woods is  an active member has participated in the several CBA with other trade lawyers.  This has included sessions, collaboration on preparation of the brief, and meetings with officials from Global Affairs Canada.  In its brief (see footnote 2), the  CBA pointed out that the proposed amendments  include phrasing that it is “highly subjective and may lead to inconsistent outcomes.”  Canada’s trade law bar is looking for increased the predictability and certainty but takes the view that that Canada’s sanction regime is actually causing  increasing “confusion and compliance challenges.  As per the brief:

To date, no guidance has been issued by Global Affairs Canada despite repeated and long-standing requests from the [association], trade lawyers and the business community.  


[1] Government Bill (House of Commons) C-47 (44-1) – First Reading – Budget Implementation Act, 2023, No. 1 – Parliament of Canada; see also Bill C-47: An Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023 ( and C-47 (44-1) – LEGISinfo – Parliament of Canada

[2] Improving-the-Economic-Sanctions-Regime; revised submission at CBA (00288795.DOCX;1)