On November 16, the Government of Canada announced additional sanctions in response to Iran’s “ongoing gross and systematic human rights violations and continued actions to destabilize peace and security”, adding six individuals and two entities to Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Iran Regulations”).

Similar to previous rounds of sanctions, these new additions are intended to target “senior officials, prominent regime supporters and entities that have participated in gross and systematic human rights violations in Iran, including brutal crackdowns on protesters and in the regime’s malign activities abroad”.

Designated persons listed in Schedule 1 of the Iran Regulations are subject to a dealings prohibition, which prohibits any person in Canada or any Canadian outside Canada from “dealing” with designated persons. Prohibitions include, for example, dealing in property, wherever situated, that is owned, held or controlled by listed persons or a person acting on their behalf, or entering into or facilitating any transaction related to a prohibited dealing.

We have significant experience in the design and implementation of sanctions-related compliance programs and internal investigations. Where breaches are identified, we work closely with clients in making voluntary disclosures and in engaging with the ensuing investigations conducted by the RCMP and Global Affairs Canada. We also regularly assist clients with the application for delisting process as well as applications for exemption permits.