On December 2, 2022, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”) in response to the Iranian regime’s “gross and systematic human rights violations and actions that continue to threaten international peace and security”. These amendments list an additional four individuals and five entities under Schedule 1 of the Regulations and took effect on November 29, 2022.

There are now over 275 parties listed under Schedule 1 of the Regulations. Among the newly listed parties are senior officials, prominent regime supporters, entities involved in transporting and developing Unmanned Aerial Vehicles (“UAVs”), commonly known as “drones”, and one media outlet – Javan News Agency.

Generally speaking, listing under Schedule 1 of the Regulations imposes a dealings prohibition, effectively an asset freeze, against the listed person. Any person in Canada or any Canadian outside Canada cannot:

– deal in any property, wherever situated, that is owned, held or controlled by a person whose name is listed in Schedule 1 or a person acting on behalf of such listed person;
– enter into or facilitate, directly or indirectly, any transaction related to such a dealing;
– provide any financial or other related services in respect of such a dealing;
– make available any goods, wherever situated, to a person listed in Schedule 1 or to a person acting on their behalf;
– provide any financial or related service to, or for the benefit of, a person listed in Schedule 1;
– export, sell, supply or ship any goods listed in Schedule 2 of the Regulations to Iran, to any person in Iran, or to a person for the purpose of a business carried on in or operated from Iran; or
– transfer, provide or disclose to Iran or any person in Iran any technical data related to the goods listed in Schedule 2 of the Regulations.

The Government of Canada has now issued six sets of amending regulations since the beginning of October in response to Iran’s “egregious behaviour, both domestically and abroad”. Businesses should continually assess their sanctions compliance in this shifting legal landscape. Regulations enacted under the Special Economic Measures Act obligate persons in Canada and Canadian citizens to disclose certain property held 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 held by Schedule 1 entities.

Canada imposes additional sanctions on the Iranian regime

News release – December 2, 2022 – Ottawa, Ontario – Global Affairs Canada

The Honourable Mélanie Joly, Minister of Foreign Affairs, today announced that Canada is imposing additional sanctions under the Special Economic Measures (Iran) Regulations.

Despite the Iranian regime intensifying efforts to brutally repress demonstrations across the country, the people of Iran continue to stand up for the rights of Iranian women and girls, and a better future for all Iranians.

Canada will not stand idly by while the regime’s human rights violations increase in scope and intensity against the Iranian people. That is why we are imposing sanctions on an additional 4 Iranian individuals and 5 entities for their roles in the regime’s gross and systematic human rights violations and actions that continue to threaten international peace and security.

This list includes:

– Morteza Talaei, Second Brigadier General of the Islamic Revolutionary Guard Corps (IRGC) and former Commander of Tehran’s Law Enforcement Forces;

– Ali Ghanaatkar Mavardiani, a senior judge, prosecutor and interrogator of the regime who worked in Evin Prison Court before being appointed the head of the District 24 (Counter-Narcotics) Prosecutor’s Office in Tehran;

– Hassan Karami, Commander of the Islamic Republic’s Law Enforcement Forces Special Units;

– Safiran Airport Services, an Iranian cargo and commercial airline that has coordinated Russian military flights between Iran and Russia, through which the Iranian regime transferred lethal Iranian-made Unmanned Aerial Vehicles (UAVs) to Russia;

– Baharestan Kish Company, a subsidiary firm of the IRGC Cooperative Foundation that has entered into agreements with the Basij Resistance Forces and the IRGC, to render research services in the technology sector, including the development of Shahed-series UAV components; and

– Javan News Agency, a media outlet under the Basij Cooperative Foundation that disseminates anti-Semitic messaging and the Iranian regime’s propaganda.

These measures are the latest example of Canada’s response to the Iranian regime’s egregious behaviour, both domestically and abroad. Canada will continue to work with international partners to address the regime’s destabilizing actions and amplify the brave Iranian voices that refuse to be silenced.


“As the Iranian regime continues to clamp down violently on Iranian society, we affirm our solidarity with the people of Iran, who have bravely called out the regime for its human rights abuses—especially those of women and girls. The Iranian regime continues to use fear and violence in suppressing the rights and freedoms of all Iranians. Today, we reiterate our support to those who refuse to endure this repression any longer.” – Mélanie Joly, Minister of Foreign Affairs

Quick facts

On October 7, 2022, Prime Minister Justin Trudeau and Deputy Prime Minister Chrystia Freeland announced Canada’s intent to implement several new measures in response to Iran’s ongoing human rights violations and threats to regional peace and security, including:

– expanding sanctions against the IRGC and introducing a new tailored regulation to ensure no sanctioned individual connected to the IRGC can enter Canada, pending the passage of Bill S-8;

– investing $76 million to strengthen Canada’s capacity to implement sanctions and ensure we can move more quickly to freeze and seize sanctioned individuals’ assets, including through a dedicated bureau at Global Affairs Canada and additional support to the RCMP to investigate and identify assets and gather evidence; and

– pursuing all the tools at our disposal, including the Justice for Victims of Corrupt Foreign Officials Act, which enables restrictive financial and property measures for foreign nationals responsible for gross violations of human rights.

In 2012, Canada designated the Islamic Republic of Iran as a supporter of terrorism under the State Immunity Act. In concert with the Justice for Victims of Terrorism Act, this designation authorizes victims to bring civil action against Iran for losses or damages from an act of terrorism with links to Iran committed anywhere in the world.