In this post we describe the sanctions recently imposed by Canada on Iranian individuals and entities following the detention and, according to the Canadian government, apparent killing of Mahsa Amini, an Iranian woman, in Iranian morality police custody.

On October 3, 2022, Canada amended the Special Economic Measures (Iran) Regulations to list an additional 25 individuals and nine entities in relation to Iran’s gross and systematic violations of human rights and/or Iran’s ongoing grave breach of international peace and security. These new sanctions follow over nine years of the Canadian government not imposing further sanctions on Iran (the 2016 amendments to Canada’s sanctions on Iran were largely a loosening of restrictions following the P5+1 agreement in relation to Iran’s nuclear program). The impetus for the new sanctions appears to have been the death in Iranian police custody of Ms. Amini. For those who follow the Canadian’ government’s policy objectives it is not surprising that this event was the catalyst for revisiting and tightening Canada’s sanctions program on Iran.

Ten Iranian individuals were designated on the basis of the Canadian government’s opinion that gross and systematic human rights violations have been committed in the Islamic Republic of Iran and that these individuals had sufficient involvement in such violations to merit being designated by Canada. Nine entities were designated on this basis including the Islamic Revolutionary Guard Corps’ Cyber Defense Command, Evin Prison, the Office of the Enjoining Right and Forbidding Evil, the Ministry of Intelligence and Security (MOIS) and the Morality Police. Many of the designated individuals lead designated entities.

In addition, 15 Iranian individuals were designated on the basis of the Canadian government’s opinion that the actions of the Islamic Republic of Iran constitute a grave breach of international peace and security that has resulted or is likely to result in a serious international crisis and that these individuals had sufficient involvement in such actions to merit being designated by Canada. These amendments signal concern about Iran’s activities in the weapons of mass destruction and/or terrorism areas. In that regard it is worth noting that the news release issued by Canada in connection with the new designations specifically referenced the Canadian government’s 2012 designation of Iran as a state sponsor of terrorism under the State Immunity Act.

Given the long-established (but possibly now somewhat diminished) business relationships between Iranian and Canadian persons it is important that Canadian businesses assess whether these new sanctions have any implications for their compliance activities.