Canada has imposed additional sanctions on 12 individuals under Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Iran Regulations”). These sanctions, announced on February 27, 2023, target “senior officials from the Islamic Revolutionary Guard Corps (IRGC) and Law Enforcement Forces (LEF) who have participated in gross and systematic human rights violations in Iran, including through the lethal suppression of demonstrations across Kurdish areas of Western Iran”. This is the ninth round of sanctions imposed against the Iranian regime since October 2022.

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.