On March 8, 2024, the Minister of Foreign Affairs announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”). These amendments list an additional two individuals in Schedule 1 of the Regulations. The announcement was released on International Women’s Day, signalling Canada’s focus on targeting human rights violations of women and girls.
The sanctioned individuals are Masoud Dorosti, the Chief Executive of the Tehran metro system, and Zohreh Elahian, a senior parliamentarian in the Majilis. Dorosti is listed for his enforcement of Iran’s mandatory hijab law on public transit. Elahian is listed for her support of the death penalty for protestors involved in the “Women, Life, Freedom” movement in Iran.
The Regulations impose a dealings prohibition against the individuals 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 March 7, 2023 are available on Global Affairs Canada’s website here.
