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Effective October 28, 2022, Canada implemented additional sanctions against Iran due to its “ongoing gross and systematic human rights violations and continued actions to destabilize regional peace and security.”  An additional four individuals and two entities have been listed under Schedule 1 of the Special Economic Measures (Iran) Regulations (the “Regulations”).

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.

An unofficial copy of the legislative amendments to the Special Economic Measures (Iran) Regulations that came into effect on October 28, 2022 are available on Global Affairs Canada’s website at here.

Author

Paul Burns has over 35 years of experience advising clients on all aspects of international trade and commodity tax, including significant experience advising on Canadian customs and export control matters. Paul obtained his LL.B. from the University of Western Ontario. For many years, he served as the practice group coordinator of the International Commercial Practice Group in Baker McKenzie's Toronto office.

Author

Brian Cacic assists clients on all substantive Canadian customs, trade sanctions and export controls issues, including complex customs valuation, tariff classification, rules of origin, marking, remissions and drawbacks. He assists clients to develop and implement effective customs and trade compliance programs, and he regularly conducts internal compliance reviews, prepares voluntary disclosures, and represents clients in Canadian customs compliance audits and enforcement actions. He also provides trade compliance and regulatory advice in connection with corporate restructurings, mergers and acquisitions, and advises clients on trade-related legislative matters.

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