On September 14, 2023, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”) in an effort to impose costs on the Iranian regime for gross and systemic human rights violations. These amendments list an additional six individuals under Schedule 1 of the Regulations and is the 14th set of amending regulations issued by Canada since October 2022. As of the most recent amendments, Canada has sanctioned 176 Iranian individuals and 192 Iranian entities.
The announcement comes on the anniversary of Mahsa Amini’s death in police custody in Iran. The individuals listed in Canada’s sanctions include the Secretary and three senior members of Iran’s Supreme Council for Cultural Revolution. Other individuals listed include the senior commander of the Islamic Revolutionary Guard Corps (IRGC) in Iran’s Kurdish provinces and the head of the Iranian Parliament’s national security and affairs committee. These sanctions are imposed in coordination with the European Union, the United Kingdom and the United States.
Schedule 1 of the Regulations imposes a dealings prohibition against the individuals and entities listed, effectively freezing any assets they hold in Canada. Individuals listed are also rendered inadmissible to Canada under the Immigration and Refugee Protection Act. For more information on the dealings prohibition, read our previous blog post on Canada’s June 2023 Iran sanctions here.
Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations made under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property owned or controlled by Schedule 1 entities and any related transactional information to the RCMP. Additionally, certain entities have a continuing duty to determine and disclose certain property owned, held or controlled by Schedule 1 entities.
Source » bakermckenzie