Regulations Amending the Special Economic Measures (Iran) Regulations: SOR/2024-72

Canada Gazette, Part II, Volume 158, Number 10

SOR/2024-72 April 24, 2024


P.C. 2024-398 April 24, 2024

Whereas the Governor in Council is of the opinion that the actions of the Islamic Republic of Iran constitute a grave breach of international peace and security that has resulted in or is likely to result in a serious international crisis;

Therefore, 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 (Iran) Regulations under paragraph 4(1)(a)footnote a and subsections 4(1.1)footnote b, (2)footnote c and (3) of the Special Economic Measures Act footnote d.

Regulations Amending the Special Economic Measures (Iran) Regulations


1 Part 1 of Schedule 1 to the Special Economic Measures (Iran) Regulations footnote 1 is amended by adding the following in numerical order:

2 Part 2 of Schedule 1 to the Regulations is amended by adding the following in numerical order:

Application Before Publication

3 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

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


(This statement is not part of the Regulations.)


Iran continues to threaten international peace and security through a myriad of destabilizing activities across the Middle East region and beyond. Iran poses a threat to the region, both through its armed forces and through its support to its allies and proxies, which includes funding, the provision of arms and training, as well as the provision of political and ideological support.


On April 14, 2024, Iran launched a broad and first-ever direct attack on Israeli military targets. Iran’s Islamic Revolutionary Guard Corps (IRGC) took responsibility for launching drones and missiles, while the Houthis, Hezbollah and Iran-linked militias in Iraq also launched strikes in a limited, but highly coordinated manner.

Iran’s attack on Israel follows a strike on an annex of the Iranian embassy in Damascus on April 1, 2024, killing up to 13 persons, including members of the IRGC. Iran’s attack against Israel is yet another example of Iran’s malign influence in the region, including through its proxies, and risks further escalation, posing a grave threat to regional and global peace and security.

International response

The Iranian attack was widely condemned by the international community. The G7 released a communiqué calling for an immediate de-escalation, condemning Iran’s actions against Israel and calling for coordination in imposing sanctions against Iran. The G7 also condemned the Iranian boarding and seizure, in breach of international law, of the Portuguese-flagged merchant vessel, which occurred while the merchant vessel was sailing near the Strait of Hormuz. On April 18, 2024, the United States and the United Kingdom imposed sanctions in a coordinated announcement against Iran to address its destabilizing actions in the region.

Canadian actions against Iran

Between 2006 and 2010, Canada implemented into domestic law several rounds of United Nations (UN) sanctions against Iran in response to its nuclear program. Canada established the Special Economic Measures (Iran) Regulations (the Iran Regulations), pursuant to the Special Economic Measures Act (SEMA) in July 2010. The Iran Regulations were based on Canada’s position that Iran’s actions amounted to a grave breach of international peace and security that resulted or was likely to result in a serious international crisis, particularly relating to Iran’s nuclear program. Canada established these new regulations in coordination with the European Union, the United States and other like-minded partners.

In October 2022, Canada amended the Iran Regulations to include circumstances of gross and systematic human rights violations. Since October 2022, Canada has imposed 16 rounds of sanctions under the Iran Regulations. Most recently, on March 8, 2024, Canada amended the Iran Regulations in response to the Iranian regime’s ongoing gross and systematic human rights violations, especially against women and girls, and continued actions to destabilize regional peace and security.

On December 7, 2023, Canada also listed two Iranian individuals under the Justice for Victims of Corrupt Foreign Officials Regulations in relation to the torture and killing of Iranian-Canadian photojournalist Zahra Kazemi in Iran in 2003.

In addition to the sanctions described above, Canada designated the state of Iran as a supporter of terrorism under the State Immunity Act in 2012. In concert with the Justice for Victims of Terrorism Act, this listing allows victims to bring civil action against Iran for losses or damages from an act of terrorism linked to Iran committed anywhere in the world. Following the designation, Canada expelled Iranian diplomats from Canada and closed its embassy in Tehran.


These sanctions intend to send a clear signal of


The Regulations Amending the Special Economic Measures (Iran) Regulations (the Regulations) list two individuals and two entities under Schedule 1 of the Iran Regulations for their role in Iran’s unprecedented attack against Israel on April 14, 2024, which constitutes a grave breach of international peace and security resulting in a serious international crisis.

Any person in Canada or Canadian outside Canada is thereby prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed individuals and entities. These measures will also render listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act. Under the Regulations, listed persons may apply to the Minister of Foreign Affairs to have their name removed from the schedule of designated persons. The Minister must determine whether there are reasonable grounds to make a recommendation to the Governor in Council for removal.

Regulatory development


Global Affairs Canada regularly engages with relevant stakeholders, including civil society organizations, 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 given the urgency to impose these measures. Publicizing the names of the persons targeted by sanctions would also have potentially resulted in asset flight prior to the coming into force of the amendments.

Modern treaty obligations and Indigenous engagement and consultation

An initial assessment of the geographical scope of the amendments 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 methods to enact sanctions in Canada. No other instruments could be considered.

Regulatory analysis

Benefits and costs

The Regulations align Canada’s efforts with those of its international partners and expose individuals and entities engaged in activities that undermine international peace and security. The measures also signal Canada’s strong condemnation of Iran’s attack on Israel.

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions is minimal. The amendments target specific individuals and entities and, as such, have less impact on Canadian businesses than traditional broad-based economic sanctions and have limited impact on the citizens of the country of the listed individuals and entities. Based on an initial assessment of available open-source information, it is believed that the newly listed individuals and entities have limited linkages with Canada and, therefore, do not have business dealings that are significant to the Canadian economy. It is therefore anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of these amendments.

Canadian banks and financial institutions are required to comply with sanctions. They will do so by adding the newly listed individuals and entities to their existing monitoring systems, which may result in a minor compliance cost.

Small business lens

With respect to the persons being listed under the Iran Regulations, an analysis under the small business lens concluded that the amendments could impact Canadian small businesses. The Iran Regulations prohibit Canadian businesses from dealing with, providing services to, or otherwise making goods available to listed persons, but do not create any direct administrative obligations related to them. While Canadian businesses may seek permits under the Iran Regulations, they are granted on an exceptional basis. Global Affairs Canada does not anticipate any applications resulting from listing these persons. Thus, there would be no incremental administrative burden arising from this requirement. Canadian small businesses are also subject to the duty to disclose under the Iran Regulations, which would represent a direct compliance requirement. However, as the newly listed persons have limited known linkages with Canada, Global Affairs Canada does not anticipate any disclosures resulting from the amendments.

One-for-one rule

The one-for-one rule does not apply, as there is no incremental change in the administrative burden on businesses. The permitting process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act; however, while permits may be granted under the Iran Regulations on an exceptional basis, given that the listed persons have limited business ties to the Canadian economy, Global Affairs Canada does not anticipate any permit applications with respect to the Iran Regulations.

Regulatory cooperation and alignment

While the Regulations are not related to a work plan or commitment under a formal regulatory cooperation forum, they align with actions taken by Canada’s allies.

Strategic environmental assessment

The Regulations 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

The subject of economic sanctions has previously been assessed for effects on gender and diversity. Although intended to facilitate a change in behaviour through economic pressure on individuals and entities in foreign states, sanctions under the SEMA can nevertheless have an unintended impact on certain groups and individuals in vulnerable situations.

Rather than affecting Iran as a whole, these targeted sanctions impact individuals and entities believed to be engaged in activities that contribute to a grave breach in international peace and security. Therefore, these sanctions are unlikely to have a significant impact on vulnerable groups, as compared to traditional broad-based economic sanctions directed toward a state, and limit the collateral effects to those dependent on targeted individuals and entities.

Implementation, compliance and enforcement, and service standards

The Regulations come into force on the day they are registered.

Consequential to being listed in the Iran Regulations, and pursuant to the application of paragraph 35.1(b) of the Immigration and Refugee Protection Act, the listed individuals will be inadmissible to Canada.

The names of the listed individuals and entities will be available online for financial institutions to review and will be added to the Consolidated Canadian Autonomous Sanctions List. This will help to facilitate compliance with the Regulations.

The Trade Commissioner Service (TCS) at Global Affairs Canada continues to assist clients in understanding Canadian sanctions regulations and, notably, the impact of the Regulations on any activities in which Canadians may be engaged, abroad and in Canada. Global Affairs Canada is also increasing outreach efforts across Canada — including engaging with businesses, universities, and provincial and territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

Under the SEMA, both Royal Canadian Mounted Police and Canada Border Services Agency officers have the power to enforce sanctions violations through their authorities, as defined under the Customs Act, the Excise Act or the Excise Act, 2001, and sections 487 to 490, 491.1 and 491.2 of the Criminal Code.

In accordance with section 8 of the SEMA, every person who knowingly contravenes or fails to comply with the 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 of not more than five years.


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