On May 3, 2023, Canada announced additional sanctions, effective retroactively as of April 28, 2023, against one Iranian entity and nine Iranian individuals under the Special Economic Measures (Iran) Regulations (the “Iran Regulations”) for “their role in gross and systemic human rights violations”. The individuals listed include members of the “so-called Morality Police unit that arrested Mahsa Amini” in September 2022, a “deputy commander of the Islamic Revolutionary Guard Corps (IRGC) forces in Sistan and Baluchistan Province, where violent clampdowns against protests resulted in the death of dozens of civilians”, and members of the “senior leadership of Paravar Pars”, an Iranian drone producer, sanctioned for supplying Russia with drones.

This is the 11th round of sanctions imposed by Canada against Iran, which brings the total number of sanctioned Iranian individuals to 156, and the total number of sanctioned Iranian entities to 192, since October 2022.

These measures have the effect of freezing any assets listed individuals and entities hold in Canada, as well as rendering those individuals listed under Part 2.1 of the Iran Regulations for “gross and systemic violations of human rights” inadmissible to Canada under the Immigration and Refugee Protection Act. If passed, Bill S-8, currently before the House of Commons’ Standing Committee on Foreign Affairs and International Development, will amend the Immigration and Refugee Protection Act to expand the scope of inadmissibility to include all individuals subject to economic sanctions under the Special Economic Measures Act.

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.