Throughout the month of March, the Government of Canada continued to vigorously pursue its sanctions designations under the country-specific sanctions enacted pursuant to Canada’s Special Economic Measures Act (SEMA). The Government announced further designations amending theSpecial Economic Measures (Russia) Regulations, the Special Economic Measures (Sudan) Regulations (Sudan Regulations), the Special Economic Measures (Burma) Regulations (Myanmar Regulations), the Special Economic Measures (Iran) Regulations (Iran Regulations), the Special Economic Measures (Haiti) Regulations (Haiti Regulations) and the Special Economic Measures (Venezuela) Regulations (Venezuela Regulations).
Additionally, the Government has issued a “general permit” in respect of the delivery of humanitarian assistance to or within Syria (Syria GP) under the Special Economic Measures (Syria) Regulations(Syria Regulations). We summarize the amendments to each individual sanctions regulation and outline the conditions of the general permit below.
Additional Sanctions in relation to Russia
The amendments list an additional ten individuals and twenty-one entities under Schedule 1 of the Russia Regulations for their alleged actions connected to Russia’s illegal annexation of Crimea, and to the continuing violation of Ukraine’s sovereignty. The amendments took effect on March 1, 2025. To date, Canada has sanctioned over 1600 individuals and 730 entities under these regulations.
Additional Sanctions in relation to Sudan
The amendments list an additional seven individuals and three entities under Schedule 1 of the Sudan Regulations for their alleged involvement in the ongoing civil conflict between the Sudanese Armed Forces (SAF) and Rapid Support Forces (RSF). The amended Sudan Regulations took effect on March 5, 2025. The newly listed individuals include leaders of SAF and RSF targeted for their refusal to negotiate a permanent ceasefire, individuals responsible for overseeing attacks on civilians, and entities involved in the procurement and funding networks for the SAF and the RSF. To date, Canada has sanctioned a total of four individuals and four entities under these regulations.
Additional Sanctions in relation to Myanmar
The amendments list an additional thirteen individuals and three entities under Schedule 1 of the Myanmar Regulations in response to allegations of human rights violations committed by individuals in Myanmar’s Ministry of Defence and the Armed Forces. The amendments entered into force on March 6, 2025. To date, Canada has sanctioned a total of 149 individuals and 92 entities under these regulations.
Additional Sanctions in relation to Iran
The amendments list an additional three individuals and four entities under Schedule 1 of the Iran Regulations citing alleged human rights violations against Iranian civilians and engagement in destabilization activities in the Middle East and globally. The amended Iran Regulations took effect on March 6, 2025. The designated individuals and entities are stated to be Iranian business people and companies linked to procurement networks that acquire and supply advanced technology supporting the Islamic Revolutionary Guard Corps’ weapons production and sales, including to Russia for its war against Ukraine. To date, Canada has sanctioned a total of 208 individuals and 254 entities under these regulations.
Additional Sanctions in relation to Haiti
The amendments list an additional three individuals under Schedule 1 of the Haiti Regulations citing allegations of acts committed which undermine the peace, security and stability of Haiti. The amended Haiti Regulations took effect on March 20, 2025. Canada aims to address the deteriorating political, security and humanitarian situation in Haiti in sanctioning these individuals. To date, Canada has sanctioned a total of 34 individuals under these regulations.
Additional Sanctions in relation to Venezuela
The amendments list an additional eight individuals under Schedule 1 of the Venezuela Regulations citing alleged activities that directly or indirectly supported human rights violations in Venezuela and/or activities that undermine Venezuela’s democracy. The amended Venezuela Regulations took effect on March 20, 2025. Canada aims to add additional pressure on the Maduro regime and to dissuade it from taking further actions that violate human rights of the Venezuelan people. To date, Canada has sanctioned a total of 139 individuals under these regulations.
Effects of designation under SEMA regulations
All of the above noted regulations impose a dealings prohibition against the individuals listed, effectively freezing any assets they hold in Canada. Specifically, these 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 enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property held by Schedule 1 parties and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property of Schedule 1 parties. An unofficial copy of the legislative amendments are linked as follows: Special Economic Measures (Russia) Regulations, Special Economic Measures (Sudan) Regulations, Special Economic Measures (Myanmar) Regulations, Special Economic Measures (Iran) Regulations, Special Economic Measures (Haiti) Regulations, Special Economic Measures (Venezuela) Regulations.
General permit issued under Syria Regulations
Canada has issued its first general permit under the SEMA 2022 amendments (see subsection 4(4), SEMA) providing authority for the Minister of Foreign Affairs to issue general permits to any persons in Canada or Canadians outside Canada to carry out a specified activity.
The Syria GP has two primary aims: (1) to ease Canada’s sanctions on Syris by permitting Canadians to contribute to humanitarian activities in and transactions with Syria, otherwise prohibited under the Syria Regulations; and (2) to signal support for Syria and Canada’s willingness to contribute to a political resolution of the Syrian conflict. The Syria GP was issued under the new authority of the Special Economic Measures Permit Authorization Order, SOR/2025-50.
Specifically, the Syria GP permits any person in Canada and Canadian outside Canada to provide funds or services to Syria in support of the delivery of humanitarian-related aid to or within Syria, including transactions with the following 7 banks currently sanctioned under the Syria Regulations:
- Commercial Bank of Syria (Schedule 1, Part 1, No. 8)
- Real Estate Bank (Schedule 1, Part 1, No. 16)
- Industrial Bank (Schedule 1, Part 1, No. 35)
- Popular Credit Bank (Schedule 1, Part 1, No. 36)
- Saving Bank (Schedule 1, Part 1, No. 37)
- Agricultural Cooperative Bank (Schedule 1, Part 1, No. 38)
- Central Bank of Syria (Schedule 1, Part 1, No. 39)
The Syria GP is valid only for 6 months from its coming into force date. Persons undertaking activities outside the scope of this permit must first submit an individual permit application to Global Affairs Canada prior to undertaking a prohibited activity.
