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On May 3, 2023, Canada announced further amendments to the Special Economic Measures (Iran) Regulations (the “Regulations”) in response to Iran’s “gross and systematic human rights violations in Iran and abroad”. These amendments list an additional nine individuals and one entity under Schedule 1 of the Regulations and entered into force on April 28, 2023.

There are now over 300 parties listed under Schedule 1 of the Regulations. The newly listed entity “exemplifies the regime’s brutality and disregard of human rights as it is the site of a record number of state executions”. The newly listed individuals include senior officials from Iran’s Islamic Revolutionary Guard Corps (IRGC) and Paravar Pars. The IRGC was responsible for “violent clampdowns against protests [that] resulted in the death of dozens of civilians” in the Sistan and Baluchistan Province of Iran and Paravar Pars has supported “Russia’s unjustifiable and full-scale invasion of Ukraine by supplying President Putin with drones”.

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 eleven sets of amending regulations since the beginning of October 2022.  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 April 28, 2023 are available on Global Affairs Canada’s website 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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