On October 3, 2022, the Government of Canada announced new sanctions against Iran through amendments to the Special Economic Measures (Iran) Regulations (the “Iran Regulations”), which came into force in July 2010.

This latest round of sanctions is introduced in response to Iran’s “gross human rights violations that have been committed in Iran, including its systematic persecution of women and in particular, the egregious actions committed by Iran’s so-called ‘Morality Police,’ which led to the death of Mahsa Amini while under their custody”, as well as “ongoing grave breach of international peace and security”, which includes “weapons proliferation and malicious cyber activity” as well as “state-sponsored disinformation to spread false narratives that attempt to justify its policies”. Amendments to the Iran Regulations were made to include persons who have participated in “gross and systematic human rights violations in Iran” as a basis for being subject to sanctions.

On September 23, 2022, the Minister of Foreign Affairs, Mélanie Joly, released a statement saying that “Canada strongly condemns the reprehensible detention and killing of Mahsa Amini [whose] death was a direct result of the systemic and continued harassment and repression of women in Iran”. Canada condemned Iran’s violence against protestors and called on Iran to refrain from committing further acts of violence to their citizens.

Following the statement from the Minister of Foreign Affairs, Prime Minister Justin Trudeau announced, on September 26, 2022, that Canada would be imposing “sanctions on dozens of individuals and entities, including Iran’s so-called morality police”.

Canada announced the imposition of new sanctions on October 3, 2022, adding 25 individuals and 9 entities to Schedule 1 of the Iran Regulations, including “senior Iranian officials and prominent entities that directly implement repressive measures, violate human rights and spread the Iranian regime’s propaganda and misinformation”. These individuals are now subject to a broad dealings ban. The individuals listed in response to gross and systematic violations of human rights are also rendered inadmissible to Canada under section 35(b) of the Immigration and Refugee Protection Act. These new sanctions are made in addition to the 41 individuals and 161 entities who have been previously sanctioned 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.