On October 3, 2022, Canada announced additional sanctions measures with respect to Iran. The Special Economic Measures (Iran) Regulations (the “Regulations”) were amended to designate an additional twenty-five individuals and nine entities under Schedule 1 related to Iran’s “gross and systematic violations of human rights” and/or ongoing grave breach of international peace and security.
Among the designated parties are senior Iranian officials and prominent entities including Iran’s Morality Police. These measures were announced in response to the gross human rights violations taking place in Iran, including systemic prosecutions of women and the most recent death of the 22-year old Iranian woman, Mahsa Amini, under the custody of Iran’s Morality Police.
Generally speaking, designation under Schedule 1 of the Regulations imposes a dealings prohibition, effectively an asset freeze, against the listed person. Any person in Canada or any Canadian outside Canada cannot:
- deal in any property, wherever situated, that is owned, held or controlled by or on behalf of a designated person whose name is listed in Schedule 1;
- enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
- provide any financial or other related services in respect of such a dealing;
- make available any goods, wherever situated, to a designated person listed in Schedule 1 or to a person acting on their behalf;
- provide any financial or related service to, or for the benefit of, a designated person listed in Schedule 1;
- export, sell, supply or ship any goods listed in Schedule 2 of the Regulations to Iran, to any person in Iran, or to a person for the purpose of a business carried on in or operated from Iran; or
- transfer, provide or disclose to Iran or any person in Iran any technical data related to the goods listed in Schedule 2 of the Regulations.
An unofficial copy of the legislative amendments to the Special Economic Measures (Iran) Regulations that came into effect on October 3, 2022 are available on Global Affairs Canada’s website at here.
