On April 25, 2024, the Government of Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”). These amendments list an additional two individuals and two entities in Schedule 1 of the Regulations.
On April 14, 2024, Iran’s Islamic Revolutionary Guard Corps and Iranian proxies launched drones and missiles into Israel, Iran’s first-ever direct attack on Israel. The newly listed individuals and entities are associated with this attack and include:
- Major General Gholam Ali Rashid, Commander of the Khatam al-Anbiya Central Headquarters,
- Brigadier General Mohammad Reza Ashtiani, Minister of Defence,
- Khatam al-Anbiya Central Headquarters, and
- Armed Forces General Staff of the Islamic Republic of Iran.
These sanctions are in coordination with Canada’s G7 allies, including the US and UK. Canada has now sanctioned 200 Iranian individuals and 250 Iranian entities in association with Iran’s threat to the Middle East region and international peace and security. To read more about Canada’s previous March 2024 sanctions against Iran, read our blog post here.
The 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:
(a) dealing in any property, wherever situated, that is owned — or that is held or controlled, directly or indirectly — by a designated person;
(b) entering into or facilitating any transaction related to a dealing in a designated person’s property;
(c) providing any financial or related services in respect of a dealing in a designated person’s property;
(d) making available any goods, wherever situated, to a listed person or to a person acting on behalf of a designated person;
(e) 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
(f) 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.
Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations made under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property owned or controlled by Schedule 1 entities and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property owned, held or controlled by Schedule 1 entities. An unofficial copy of the legislative amendments to the Special Economic Measures (Iran) Regulations that came into effect on April 24, 2024 are available on Global Affairs Canada’s website here.
