Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

Canada's Office of Superindendent of Financial Institutions Issues Notice on Libyan Sanctions

On March 1, 2011, the Office of Superintendent of Financial Institutions Canada released a notice regarding the new regulations implementing the United Nations Resolution on Libya and taking special economic measures. For a copy of this notice, please go to the following link -

This notice is directed to the attention of all Canadian banks, authorized foreign banks, trust companies, loan companies, cooperative credit societies, life insurance companies, and fraternal benefit societies.

The notice discusses the United Nations and Canada's new trade restrictions and economic sanctions against Libya and the Libyan regime.

In addition, the notice discusses the new searching, freezing, monitoring, disclosure and due diligence obligations on Canadian financial institutions contained in the new Libya Regulations. Implementation of the Libya Regulations requires financial institutions to identify accounts to which the asset freeze applies, and also to monitor financial transactions to ensure that transactions connected to designated persons are identified, blocked and reported as appropriate, including measures at any branches in Canadian financial institutions.

The financial institutions are the searchers and gatekeepers. Canadian financial institutions have a critical role to play.

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