Summary: Canadian Sanctions Guidance for the Aerospace & Defence Sector
Source: Global Affairs Canada (last updated April 20, 2026). No additional sources were used.
What This Is
This is a guidance document from Global Affairs Canada aimed at helping Canadian aerospace and defence organizations understand and comply with Canadian sanctions laws. It is not a legal opinion — the government recommends that organizations maintain their own internal compliance program and consult legal counsel when needed.
Who It Applies To
When Canada imposes sanctions, all persons in Canada and Canadians abroad face restrictions on dealing or collaborating with sanctioned countries, or with specific listed individuals and entities. This includes aerospace and defence companies involved in importing, exporting, or providing services related to goods and technologies.
Export and Import Controls
In some situations, a transaction may legally require both an approved export control permit and a separate sanctions permit. Even if you hold a valid export permit, a transaction involving a listed person is still prohibited without a sanctions permit. Similarly, if the destination country is subject to sanctions — even if none of the parties involved are listed — a sanctions permit may still be required.
Dual-use goods (items that can serve both civilian and military purposes) receive particular attention. Certain dual-use goods and technologies may be prohibited under specific sanctions regulations.
Russia and Belarus are specifically highlighted. Regulations targeting Russia and Belarus prohibit the sale or supply of many goods and technologies (regardless of whether they could be used to make weapons), services related to aviation and aerospace, and research or technical assistance.
Canada is also a member of the Global Export Control Coalition (GECC), which monitors battlefield-bound goods through a Common High Priority Items List (CHPL). Canada has incorporated these items into its Russia sanctions regulations.
Arms and Related Material
Under Canadian sanctions law, “arms and related material” broadly covers weapons, ammunition, military equipment (including military vehicles), paramilitary equipment, and their spare parts.
When assessing whether something qualifies, the guidance says to consider: whether the good is specially designed or modified for military use; whether its intended end use supports a military program; whether it is going to a military entity or defence contractor; and whether the transaction might benefit a listed person with military connections.
Related service prohibitions may also apply, including financial services, insurance, and other services tied to the manufacture and export of prohibited goods.
Due Diligence
Sanctions in Canada change frequently. Companies are encouraged to:
- Screen proposed engagements against the UN Security Council Consolidated List and Canada’s Consolidated Autonomous Sanctions List.
- Look beyond direct dealings — under most relevant legislation, it is prohibited to facilitate a transaction related to a listed individual or entity, even indirectly through a third party that may not be Canadian and may be located outside Canada.
- Ask questions such as: Does my client have ties to listed persons, through family members, subsidiaries, or intermediary banks? Does this activity benefit a listed person in any way?
Red Flags
Some individuals and entities may attempt to circumvent Canadian sanctions. If a transaction raises red flags, companies should ask: Can the red flags be explained? Can you confirm the legitimacy of the parties and the transaction? If doubt remains, legal advice is strongly recommended.
Enforcement
Information on reporting sanctions violations and penalties for non-compliance is available through Global Affairs Canada’s sanctions enforcement guidance. Questions can be directed to the Global Affairs Canada Sanctions Bureau.
Confidence Check
Everything in this summary is directly supported by the source page. No claims were extrapolated or inferred beyond what the document states. I did not use any additional sources. One important caveat: this is a summary of government guidance, not legal advice — the page itself notes that organizations should consult private legal counsel for their specific situations.
