On June 24, 2024, Canada announced that nine individuals and two entities were added to the Special Economic Measures (Hamas Terrorist Attacks) Regulations (the “Regulations”), created in response to the attacks by Hamas in Israel beginning on October 7, 2023. The amended Regulations entered into force on June 24, 2024.
The sanctions target individuals and entities with roles in Hamas’ financial network. Each named party has participated directly or indirectly in facilitating, supporting, and providing funding considered integral to the planning and execution of the October 7, 2023 attacks on Israel.
The amended Regulations impose a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Specifically, the Regulations prohibit any person in Canada and any Canadian outside Canada from:
- dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
- entering into or facilitating any transaction related to a dealing in a designated person’s property;
- providing any financial or related services in respect of a dealing in a designated person’s property;
- making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
- transferring or providing any property other than goods to a listed person or to a person outside Canada who is not Canadian for the benefit of a designated person; or providing any financial or related services to or for the benefit of a designated person.
Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act.
Note that Hamas has been listed as a terrorist entity under Canada’s Criminal Code since November 27, 2002 and was already subject to similar prohibitions as those outlined in the Regulations. Specifically, the Criminal Code prohibits persons in Canada and Canadians outside of Canada from knowingly:
- dealing directly or indirectly with property owned or controlled by or on behalf of the terrorist group (Terrorist Property);
- entering into or facilitating, directly or indirectly, any transaction in respect of Terrorist Property; or
- providing any financial or other related services in respect of Terrorist Property.
Terrorist Property may also be subject to seizure, restraint, or forfeiture.
An unofficial copy of the legislative amendments to the Special Economic Measures (Hamas Terrorist Attacks) Regulations that came into effect on May 24, 2024 is available on Global Affairs Canada’s website here.
