On December 9, 2022, Canada will Special Economic Measures (Iran) Regulations (“regulation”) in response to those “who are complicit in gross and systematic human rights abuses in Iran.” These amendments list an additional 22 persons under Schedule 1 of the Rules and will take effect on December 7, 2022.
There are now more than 290 parties listed on Schedule 1 of the Rules. Among the newly listed political parties are “senior members of Iran’s judiciary, prison system and law enforcement agencies, as well as political leaders such as senior aides to the regime’s supreme leader and senior officials of the state media.” It is
Generally speaking, a Listing under Schedule 1 of the Rules imposes a trading ban, effectively an asset freeze, on the Listing Party. Canadians in or outside of Canada cannot:
- Transactions in property owned, held or controlled by persons named in Schedule 1 or acting on behalf of persons on the List, wherever located.
- enter into or facilitate, directly or indirectly, any transaction related to such transaction;
- provide financial or other related services in connection with such transactions;
- Make the Products available to the persons listed in Schedule 1 or to persons acting on their behalf, wherever they may be located.
- Provide financial or related services to, or for the benefit of, any person on Schedule 1.
- export, sell, supply, or ship any goods listed in Schedule 2 to the Regulations to Iran, to any person in Iran, or to any person for the purposes of any business conducted or operated in Iran;Also
- Transfer, provide or disclose to Iran or any Iranian person any technical data relating to any goods listed in Schedule 2 of the Regulations;
The Canadian government has now issued seven sets of revised regulations since the beginning of October. Businesses must continuously assess their compliance with sanctions in this changing legal landscape.Regulations enacted under Economic Special Measures Law Requires Canadian persons and Canadian citizens to disclose to the RCMP certain property held by Schedule 1 entities and related transaction information. In addition, certain entities have ongoing obligations to determine and disclose certain assets held by Schedule 1 entities.
Unofficial copy of law change Special Economic Measures (Iran) Regulations Effective December 7, 2022, the rule is available on the Global Affairs Canada website here.