Canada has imposed additional sanctions against the Iranian regime in response to their “intensifying efforts to brutally repress demonstrations across the country”, adding four individuals and five entities to Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Iran Regulations”). These sanctions came into effect on November 29, 2022, and were followed by an announcement from Minister Mélanie Joly.

This new round of sanctions is intended to target individuals and entities “for their roles in the regime’s gross and systematic human rights violations and actions that continue to threaten international peace and security”.

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.