On March 23, 2023, Canada imposed additional sanctions against Iran under the Special Economic Measures (Iran) Regulations (the “Iran Regulations”). This tenth round of sanctions includes eight individuals and two entities, who have been targeted for “gross and systemic human rights violations”. According to Canada, “[t]he sanctioned entities support the Iranian regime by helping them disrupt and manipulate the online communications of those protesting the regime or by supplying the [Law Enforcement Forces] with tactical equipment used in the brutal suppression of demonstrations”.

Following the detention and death of Mahsa Amini in September 2022, Canada announced its “intention to implement several new measures to respond to Iran’s ongoing human rights violations and the threats Iran poses to international peace and security”. Since October 2022, Canada has sanctioned 147 individuals and 191 entities under the Iran Regulations.

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.