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On November 16, 2022, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”) in response to the Iranian regime’s “ongoing gross and systematic human rights violations and continued actions to destabilize peace and security”. These amendments list an additional six individuals and two entities under Schedule 1 of the Regulations and took effect on November 10, 2022.

There are now over 250 parties listed under Schedule 1 of the Regulations. Among the newly listed parties are senior officials, prominent regime supporters as well as entities involved in “the sale of weapons and the provision of Iranian military personnel to train and assist Russian forces on the use of Iranian weapons”.

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 five sets of amending regulations since the beginning of October in response to Iran’s “gross and systematic human rights violations” and ongoing breach of international peace and security. 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.

An unofficial copy of the legislative amendments to the Special Economic Measures (Iran) Regulations that came into effect on November 10, 2022 are available on Global Affairs Canada’s website at here.


Julia Webster is a disputes and international trade lawyer. She advises companies on trade remedies, free trade agreements, blocking measures, customs compliance, anti-corruption laws, economic sanctions, AML compliance, supply chain ethics, and cross-border M&A.


Eloise Somera is an Articling Student from Baker McKenzie, Toronto office.

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