Please note that there have been some small amendments to the CSA Guide to Suppression of Terrorism and Canadian Sanctions Reporting (STCS) applicable to registered firms, exempt dealers and exempt advisers. The STCS has been amended to reflect the fact that as of June 30, 2021, the Justice for the Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law) no longer requires a monthly “nil” report to be filed with a registered firm’s principal regulator. Now, a report is only required to be filed under that Act where a registered firm determines that it is in fact in possession of property of a designated person. A “nil” report is still required to be filed under the Criminal Code (Canada) on a monthly basis, by the 14th day of each month to the firm’s principal regulator. The CSA’s revised guidance can be found here.
September 30, 2021