On October 19, 2022, Canada announced its third round of sanctions measures against the Iranian regime in response to its “ongoing gross and systematic human rights violations and continued actions to destabilize regional peace and security.” These measures add an additional six individuals and four entities to Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Regulations”).
Among the newly listed parties are Seyyed Majid Mirahmadi (the current Deputy Interior Minister of Iran), the Guardian Council, Fars News Agency, and the Expediency Discernment Council which comprises of senior officials that advise Iran’s Supreme Leader in all policy areas.
Generally speaking, listing 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 a person whose name is listed in Schedule 1 or a person acting on behalf of such listed person;
- 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 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 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 19, 2022 are available on Global Affairs Canada’s website at here.