Canada’s foreign influence registry is extremely broad – much more so than registries in peer jurisdictions. It was designed to capture ordinary commercial activities with very few exemptions. Fasken’s political law team can help your organization understand when registration is required and avoid significant penalties.
Many organizations do not realize that an informal, unwritten or unpaid relationship with a state-owned enterprise or other foreign-linked entity can trigger a mandatory registration obligation, even where the underlying activity is legitimate business. The registration rules turn on flexible concepts like “arrangement” and “foreign principal” where interpretations are made on a case-by-case basis by independent bureaucrats.
We help clients determine whether their relationships and activities are caught, prepare and file registrations, and help manage the onerous continuous disclosure obligations. We also assist with enterprise-wide compliance programs, staff training and internal audits to identify and manage registration risk before it becomes a problem.
Where necessary, our leading team of political law lawyers can defend organizations subject to investigations or enforcement proceedings by the Commissioner.
Our experience extends to navigating exemptions and grey areas, including the interplay with solicitor-client privilege and other professional obligations, and to advising on the practical realities of dealing with a new regulator as it develops its enforcement approach.
Contact any of our lawyers to learn more about Canada’s foreign influence registry or for help navigating compliance.
