Regulations Amending the Special Economic Measures (Zimbabwe) Regulations: SOR/2023-64

Canada Gazette, Part II, Volume 157, Number 8

SOR/2023-64 March 27, 2023


P.C. 2023-266 March 27, 2023

Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Special Economic Measures (Zimbabwe) Regulations under subsections 4(1)footnote a and (3) of the Special Economic Measures Act footnote b.

Regulations Amending the Special Economic Measures (Zimbabwe) Regulations


1 Items 2, 5, 8, 11 to 14, 16, 17, 20, 23, 25, 26, 30, 31, 33, 34, 40 to 42, 47, 51, 54, 57, 58, 60, 63, 66, 68, 70, 71, 78, 79, 85 to 87, 89, 92 to 98, 102, 104 to 109, 111 to 113, 116, 118 to 123, 125, 126, 129, 134, 136 to 138, 140, 141, 143 to 145, 147 to 153, 155 to 157, 159 to 163, 167 to 171, 173, 175, 176 and 178 to 181 of the schedule to the Special Economic Measures (Zimbabwe) Regulations footnote 1 are repealed.

Application Before Publication

2 For the purpose of paragraph 11(2)(a) of the Statutory Instruments Act, these Regulations apply according to their terms before they are published in the Canada Gazette.

Coming into Force

3 These Regulations come into force on the day on which they are registered.


(This statement is not part of the Regulations.)


The proposed amendments to the Special Economic Measures (Zimbabwe) Regulations (the Regulations) remove 100 individuals from the Schedule of the Special Economic Measures (Zimbabwe) Regulations given that the criteria for listing these individuals on the Schedule are no longer met.


The Special Economic Measures (Zimbabwe) Regulations enacted by Canada under the Special Economic Measures Act (SEMA) were registered on September 4, 2008, after Zimbabwe entered a state of violent political crisis in the aftermath of the presidential elections held in 2008. Former President Robert Mugabe led a campaign of terror against the opposition party and, despite winning the election, continued to implement brutal attacks against the political opposition. The violent crackdown in Zimbabwe caused a grave breach of international peace and security that resulted in a serious international crisis. The Special Economic Measures (Zimbabwe) Regulations came into force in order to respond to the gravity of the situation in Zimbabwe. One hundred and seventy-seven persons and four entities were designated on the Schedule to the Special Economic Measures (Zimbabwe) Regulations.

These measures prohibit persons in Canada and Canadians abroad from exporting, selling, supplying or shipping arms and related material, wherever situated, to Zimbabwe or to any person in Zimbabwe.

Moreover, the Regulations prohibit any owner or master of a Canadian vessel, within the meaning of section 2 of the Canada Shipping Act, 2001, or any operator of an aircraft registered in Canada, from carrying, causing to be carried or permitting to be carried, arms and related materials, wherever situated, destined for Zimbabwe or any person in Zimbabwe.

Furthermore, the Regulations prohibit any person in Canada and or outside Canada from providing any person in Zimbabwe with technical or financial assistance, technical or financial services, or brokerage or other services related to the supply, sale, transfer, manufacture or use of arms and related materials.

The Special Economic Measures (Zimbabwe) Regulations prohibit persons (individuals and entities) in Canada and Canadians outside Canada from conducting the following activities with listed individuals and entities:

The Regulations also prohibit any person from landing in Canada, or flying over Canada, an aircraft that is registered in Zimbabwe, except if landing in Canada is necessary to safeguard human life; and they prohibit any person in Canada and any Canadian outside Canada from doing anything that causes, assists or promotes, or is intended to cause, assist or promote, any act or thing described above as prohibited.


Amendments to the Regulations will serve to renew Canada’s sanctions regime in Zimbabwe and bring it up to date with present realities in the country. Further, this will have the effect of bringing Canada’s approach back into line with those of like-minded partners. The amendment will also demonstrate that Canada’s sanctions regime is flexible and responsive to the evolving circumstances in Zimbabwe, addressing in part what has become a key irritant between Canada and many African states who have criticized the perceived rigidity of Canada’s regime.


The Regulations Amending the Special Economic Measures (Zimbabwe) Regulations will remove 100 individuals from the Schedule of the Regulations, including one that was mistakenly named twice. Following these removals, there will be 76 individuals remaining on the sanctions list.

Regulatory development


Global Affairs Canada engages regularly with relevant stakeholders including civil society organizations and cultural communities and other like-minded governments regarding Canada’s approach to sanctions implementation.

With respect to the amendments, public consultation would not have been appropriate, as publicizing the names of the removed persons previously targeted by sanctions would risk creating negative media attention prior to the coming into force of the Regulations.

Modern treaty obligations and Indigenous engagement and consultation

An initial assessment of the geographical scope of the initiative was conducted and did not identify any modern treaty obligations, as the amendments do not take effect in a modern treaty area.

Instrument choice

Regulations are the sole method to enact sanctions in Canada. No other instrument could be considered.

Regulatory analysis

Benefits and costs

The application of sanctions in 2008 was intended to send a signal to the Government of Zimbabwe that Canada would not accept the violent state-sponsored crackdown which followed the 2008 Presidential elections and the continued violations of human rights perpetrated by senior officials of the ruling ZANU-PF party.

Canadian banks and financial institutions are required to comply with the sanctions. They have done so by adding the new prohibitions to their existing monitoring systems, which may have resulted in minor compliance costs.

The proposed amendments to the Regulations will not create additional compliance costs for businesses because the result will be a reduction, rather than an increase in the number of listed individuals. Therefore, there will be no costs coming as a result of these amendments.

Small business lens

No significant loss of opportunities for small businesses is expected as a result of the amendments. To facilitate compliance by small businesses, Global Affairs Canada is in the process of conducting outreach with stakeholders to better inform them of changes to the Regulations. This includes updates to the sanctions website.

One-for-one rule

The one-for-one rule does not apply to the amendments, as they do not impose an incremental administrative burden on businesses.

Regulatory cooperation and alignment

While the amendments are not related to a work plan or commitment under a formal regulatory cooperation forum, they align with actions taken by like-minded partners.

Strategic environmental assessment

The amendments are unlikely to result in important environmental effects. In accordance with the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary scan concluded that a strategic environmental assessment is not required.

Gender-based analysis plus (GBA+)

The focus of the listings is on entities and specific individuals with close linkages to the ruling ZANU-PF party. This results in minimizing collateral effects on the wider population of Zimbabwe.

Exceptions are included in the Regulations, including, among others, to allow for the delivery of humanitarian assistance to provide some mitigation of the impact of sanctions on vulnerable groups. The Minister of Foreign Affairs can also issue permits pursuant to the Special Economic Measures (Zimbabwe) Permit Authorization Order that would allow successful applicants to carry out a specified activity or transaction that is otherwise restricted or prohibited under the Regulations.


Removals from the Schedule of the Regulations are justified given that a number of individuals are deceased, and many others have either been expelled from the ruling ZANU-PF party or departed from government. There are also several individuals who are former spouses or children who are no longer associated with listed individuals. The proposed changes will put Canada in line with like-minded countries, including Australia, the European Union, the United Kingdom and the United States, who have continually updated their respective sanctions lists. This amendment to Canada’s Zimbabwe sanctions regime will also be well received by African states, especially those within the Southern African Development Community (SADC), who have long advocated for the removal of sanctions and a more cooperative approach to engagement with Zimbabwe.

Additional measures within the regulations, such as those which globally prohibiting the exporting, selling, supplying or shipping arms and related material to Zimbabwe, will remain in place. While it is justified to remove restrictions on specific individuals, the situation in Zimbabwe writ large remains problematic and has not been satisfactorily addressed in order to justify a full lifting of these wider measures.

Implementation, compliance and enforcement, and service standards

Canada’s sanctions Regulations are enforced by the Royal Canadian Mounted Police and the Canada Border Services Agency. In accordance with section 8 of the Special Economic Measures Act, every person who willfully contravenes the Special Economic Measures (Zimbabwe) Regulations is liable, upon summary conviction, to a fine of not more than $25,000 or to imprisonment for a term of not more than one year, or to both; or, upon conviction on indictment, to imprisonment for a term or not more than five years.


Laird Hindle
Deputy Director
Southern and Eastern Africa Bilateral Relations Division
Global Affairs Canada