About this webinar
Global Affairs Canada (GAC) updated its deemed ownership guidance on October 13, 2026, making it explicit that the holdings of all listed persons should be evaluated together when determining whether an entity is owned or controlled under the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA). Under this aggregate approach, an unlisted entity can fall under Canada's dealings prohibition even when no single listed person holds a majority stake.
Join Kharon’s Olivia Valone and Andrew Sobotka for a 20-minute briefing on what GAC’s guidance clarifies and how compliance teams can effectively screen for aggregate ownership and control risk.
Topics will include:
Aggregate Ownership: What GAC's updated guidance says about considering stakes held by multiple listed parties together, and when their combined total brings unlisted entities under the dealings prohibition.
Control Below 50% Ownership: Key indicators of control beyond equity that GAC identifies, including board appointment rights, shareholder agreements, front persons, and share transfers around listing dates.
Screening Under the Updated Guidance: How organizations can integrate high-quality ownership and control data into existing customer and transaction screening systems.
