2025 Annual Report on Canadian Coast Guard’s Implementation of Directions for Avoiding Complicity in Mistreatment by Foreign Entities

Background

The Avoiding Complicity in Mistreatment by Foreign Entities Act (Act) came into force on July 13, 2019, which authorized the Governor in Council (GiC) to issue Directions to the deputy heads of federal departments and agencies that conduct information sharing activities with foreign entities where there could be a substantial risk of mistreatment.

Introduction

The Act requires that the deputy head submit a report to the appropriate minister, before March 1 of each year with respect to the implementation of the directions during the previous calendar year.

This report covers the period from January 1, 2025, until December 31, 2025. Its contents describe how Canadian Coast Guard’s (CCG) information sharing activities were conducted within the constraints of the statutory obligations of the Act.

Adherence to the Act under transition

On September 4, 2019, the GiC issued the Directions for Avoiding Complicity in Mistreatment by Foreign Entities (the Directions) to the Deputy Minister of Fisheries and Oceans. From April 1, 2025, to September 1, 2025, during which time the CCG formed part of Fisheries and Oceans Canada (DFO), the CCG operated in accordance with DFO’s policies, procedures, and governance framework supporting compliance with the Act.

The Directions pertain to the request and disclosure of information that would result in a substantial risk of mistreatment of an individual by a foreign entity, as well as the use of information that is likely to have been obtained as the result of mistreatment of an individual by a foreign entity. Under the Act, the Deputy Minister must make a copy of the Directions public. The Directions issued to the Deputy Minister can be found on the Orders in Council Website.

Effective September 2, 2025, responsibility for the CCG was transferred from DFO to the Department of National Defence (DND) through an Order in Council made pursuant to the Public Service Rearrangement and Transfer of Duties Act. During the remainder of the reporting period, the CCG continued to apply the existing DFO policy framework and associated practices, with consideration to the operational, administrative, and governance changes associated with the departmental transition.

The submission of the 2025 report was delayed due to the complexities associated with administrative and coordination requirements arising from the transfer of the CCG from DFO to DND.

Cases of substantial risk

The following section outlines, by category of activity, any cases that the CCG identified as presenting a substantial risk of mistreatment pursuant to the Directions for the period from January 1, 2025, to December 31, 2025:

disclosures of information: The Canadian Coast Guard had no cases
requests for information: The Canadian Coast Guard had no cases
use of information: The Canadian Coast Guard had no cases

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2026-07-07

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2025 Annual Report on Canadian Coast Guard’s Implementation of Directions for Avoiding Complicity in Mistreatment by Foreign Entities

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