General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations: SOR/2025-61

Canada Gazette, Part II, Volume 159, Number 6

Registration
SOR/2025-61 February 28, 2025

SPECIAL ECONOMIC MEASURES ACT

The Minister of Foreign Affairs issues the annexed General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations under paragraph 2(b) of the Special Economic Measures Permit Authorization Order footnote a and subsection 4(5)footnote b of the Special Economic Measures Act footnote c.

Ottawa, February 27, 2025

Mélanie Joly
Minister of Foreign Affairs

General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations

General Permit

Authorized activities and transactions

1 Any person in Canada or Canadian outside Canada may, under this General Permit, carry out any of the following activities and transactions that are otherwise prohibited under the Special Economic Measures (Syria) Regulations if the activities and transactions are aimed at the democratization and stabilization of Syria or the delivery of humanitarian assistance to or within Syria:

Validity Period

180 days

2 This General Permit ceases to have effect on the 180th day after the day on which it comes into force.

Coming into Force

Registration

3 This General Permit comes into force on the day on which it is registered.

SCHEDULE

(Paragraph 1(a))

Entities

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the General Permit.)

Issues

Economic sanctions against Syria were first imposed under the Special Economic Measures Act (SEMA) in May 2011 as a response to the Assad regime’s violent crackdown on Syrians seeking democracy and respect for human rights. Now that the Assad regime has collapsed, there is room for Canada and the international community to contribute towards a sustainable and inclusive political resolution to the Syrian conflict, to increase humanitarian assistance, to foster good governance, and to promote accountability for atrocities and human rights violations in Syria. To address the dire humanitarian needs, priority is being placed on food security, healthcare, early recovery support, and targeted sanctions relief to bolster humanitarian assistance.

Background

Protests for democratic reforms began in March 2011 in various cities across Syria. The violent crackdown by the Assad regime on peaceful protesters led to large-scale civilian death, injury, and displacement. It is estimated that well over 250 000 people died in the conflict from 2011 to 2024, with hundreds of thousands more wounded. The situation in Syria remains one of the world’s largest displacement crises, with more than 7.2 million internally displaced Syrians and 6.2 million Syrian refugees around the world, including in neighbouring countries Jordan, Lebanon, Türkiye, Iraq as well as Egypt. The actions of the Assad regime caused a grave breach of international peace and security and resulted in an unprecedented humanitarian crisis in the region.

In response to these actions, Canada imposed a broad range of restrictions against the (now former) Syrian regime in 2011 and has since made thirteen 13 amendments to the Special Economic Measures (Syria) Regulations (the Regulations), the most recent of which was in April 2017. The Regulations restrict persons (individuals and entities) in Canada and Canadian outside of Canada in dealing in property, providing or acquiring financial services, taking part in financial transactions, and providing goods or other services to any person listed in Schedule 1 of the Regulations, which includes nearly 300 individuals and 56 entities.

Facilitated by the Justice for Victims of Terrorism Act, Canada designated Syria as a state supporter of terrorism under the State Immunity Act (SIA) in 2012. This listing represented one more step in holding the Syrian government responsible for its actions, including support for terrorist groups such as Hizballah, Palestinian Islamic Jihad, and Hamas.

Furthermore, the United Nations (UN) Security Council put in place counterterrorism sanctions that relate to Syria. For instance, Hayat Tahrir al-Sham (HTS) and Jaysh al-Muhajirin wal-Ansar (JMA) are designated terrorist groups and subject to sanctions (arms embargo, travel ban, asset freeze) further to decisions of the ISIL (Da’esh) and Al-Qaida Sanctions Committee (under UN Security Council Resolutions 1267/1989/2253). Canada usually implements these UN Security Council resolutions into domestic law through the development of regulations under the United Nations Act (UNA). In the particular case of HTS, its listing as a terrorist organization under the Criminal Code satisfies Canada’s international legal obligations under the UN sanctions regime.

Post-fall of the Assad regime

On December 8, 2024, opposition forces led by HTS succeeded in ending the rule of the Assad regime in Syria. An HTS-led transitional government has now been formed and is making efforts to put Syria on the path towards political stabilization and a peaceful transition. However, the security landscape remains fragile and complex, with various armed groups continuing to exert control in some parts of the country.

It is estimated that over 16 million people — approximately 70% of the country’s population—continue to urgently require humanitarian assistance. The current Regulations include a humanitarian exemption to carry out limited humanitarian assistance for the purpose of safeguarding human life, disaster relief, democratization, stabilization or providing food, medicine or medical supplies or equipment, but only to or by an international organization with diplomatic status, a UN agency, the International Red Cross and Red Crescent Movement, or a non-governmental organization that has entered into a grant or contribution agreement with Global Affairs Canada. The limitations of the humanitarian exemption, combined with the extensive sanctions measures related to Syria, are hindering the direct and broader humanitarian aid that could be offered by Canadians to bolster support and contribute to stabilization and a sustainable transition.

International response to the fall of the Assad regime

On December 12, 2024, G7 leaders reaffirmed their commitment to the people of Syria and full support for an inclusive Syrian-led and Syrian-owned political transition process in the spirit of the principles of UN Security Council Resolution 2254. They also called on all parties to preserve Syria’s territorial integrity and national unity and to respect its independence and sovereignty.

Since December 2024, the United States (U.S.), the United Kingdom (U.K.), the European Union (EU), and others have expressed a willingness to contribute to humanitarian assistance for the Syrian people during this period of transition. The U.S. Treasury issued Syria General Licence No. 24 on January 6, 2025, titled “Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances,” valid for a period of six months (i.e. until July 2025). On February 12, 2025, the U.K. issued a General Licence to allow continued humanitarian activity in Syria and confirmed its intention to amend the Syria sanctions regime, including its Regulations. On February 24, the EU announced that it is suspending restrictive measures in key economic sectors, including energy, finance and transport.

On February 13, 2025, France hosted the Paris Conference on Syria. A Joint Statement from those present, including Canada, confirmed their wish to work together to ensure the success of the post-Assad transition in the framework of a process that must be Syrian-led and Syrian-owned, in the spirit of the fundamental principles of Security Council Resolution 2254 (2015), in order to enable the Syrian people to build a safer, more promising, prosperous and more peaceful future. On February 15, G7 Foreign Ministers met on the margins of the Munich Security Conference for the first time under Canada’s 2025 Presidency and welcomed the outcomes of the Paris Conference. They reiterated their shared commitment to the people of Syria and their support for an inclusive political transition process, in the spirit of UN Security Council Resolution 2254.

Canada’s response to the fall of the Assad regime

Along with its international partners, Canada seeks to support Syrians during this important period of political transition.

Canada welcomed the end of the Assad regime in Syria on December 8, 2024. Canada has reaffirmed its commitment to the people of Syria and announced further government funding on January 13, 2025, for assistance to be delivered through the UN and experienced humanitarian partners to address urgent needs in Syria. The funding will help provide clean water and food; protection services, including for the prevention and mitigation of and response to gender-based violence; sanitation and hygiene services; and health services.

On December 20, 2024, Canada and the Netherlands welcomed an extension to allow for submissions related to their case at the International Court of Justice (ICJ) to appropriately reflect recent developments. The purpose of the ICJ case is to hold Syria to account for gross and systematic violations of the Convention against Torture since at least 2011, in the wake of the Assad regime’s brutal crackdown. Canada and the Netherlands reiterated the firm belief that there can be no sustainable peace and lasting reconciliation in Syria without accountability.

On February 7, 2025, Prime Minister Justin Trudeau announced the appointment of the Honourable Omar Alghabra as Canada’s Special Envoy for Syria. The Prime Minister also spoke with the interim President of Syria, Ahmed al-Sharaa, on February 13 and offered congratulations on the success of ending the Assad regime. He noted that Canada has welcomed over 100 000 Syrian refugees since 2015 and underscored that Canada continues to stand with Syrians in their pursuit of a more just and inclusive society. Both welcomed the efforts undertaken by the transitional government to put Syria on the path towards future success and acknowledged the challenges associated with the current sanctions on Syria.

Objective

The General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations (the Ministerial Order) aims to:

Description

The Ministerial Order is issuing a general permit (the General Permit) under the Special Economic Measures Permit Authorization Order that allows any person (individuals and entities) in Canada and Canadian outside Canada to carry out activities and transactions that would otherwise be prohibited under the Regulations in support of the delivery of humanitarian aid, democratization and stabilization regarding Syria.

Specifically, any person in Canada and Canadian outside Canada are allowed to provide any funds or services to Syria in support of the delivery of humanitarian-related aid to or within Syria, including transactions with the following 7 banks currently sanctioned under the Regulations:

  1. Commercial Bank of Syria (Schedule 1, Part 1, No. 8)
  2. Real Estate Bank (Schedule 1, Part 1, No. 16)
  3. Industrial Bank (Schedule 1, Part 1, No. 35)
  4. Popular Credit Bank (Schedule 1, Part 1, No. 36)
  5. Saving Bank (Schedule 1, Part 1, No. 37)
  6. Agricultural Cooperative Bank (Schedule 1, Part 1, No. 38)
  7. Central Bank of Syria (Schedule 1, Part 1, No. 39)

The General Permit is valid for a period of 6 months from the date the Ministerial Order enters into force.

For any activity or transaction outside of the scope of the General Permit mentioned above, any person in Canada or Canadian outside Canada are prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed persons under the Regulations. Other prohibitions under the Criminal Code as well as pursuant to UN Security Council resolutions may still apply for humanitarian-related and other activities. Additional information is available in the FAQs available on the Canadian sanctions webpage of Global Affairs Canada’s website.

Regulatory development

Consultation

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. Additionally, Global Affairs Canada engages with relevant stakeholders, including civil society organizations and financial institutions, regarding sanctions compliance as well as individual permit applications and authorizations.

In recent months, since the fall of the Assad regime, stakeholders and subject matter experts have called for increased Canadian assistance in response to the humanitarian needs in Syria. Although all Canadians are allowed to use the General Permit, it is expected that stakeholders that will benefit from this measure will primarily be civil society organizations, non-profit organizations, charitable organizations, or individuals and groups from the Syrian diaspora in Canada wanting to send funds or offer services to boost humanitarian assistance in Syria. This regulatory development should not have any adverse impact on relevant stakeholders given that the General Permit is easing restrictions and temporarily removing barriers to specific humanitarian-related activities and transactions regarding Syria.

Canada’s Special Envoy for Syria, the Honourable Omar Alghabra, Member of Parliament for Mississauga Centre, advises the Prime Minister and the Minister of Foreign Affairs on Canadian efforts to support the Syrian people in addressing their pressing needs. To do this, he consults with a range of stakeholders, including subject matter experts, regional actors, and international partners, to promote inclusive governance and ensure the protection of human rights.

Public consultation pertaining to the General Permit would not have been appropriate or possible due to sensitive foreign policy considerations and time pressures to support a sustainable transition in Syria. Through the implementation of the General Permit and other engagement related to Syria, Canada will remain engaged and exchange views with stakeholders on how Canadian efforts can best support the immediate delivery of humanitarian assistance to Syria.

Modern treaty obligations and Indigenous engagement and consultation

An initial assessment of the geographical scope of the General Permit was conducted and did not identify any modern treaty obligations, as the Order does not take effect in a modern treaty area.

Instrument choice

Regulatory options such as a ministerial order are the sole method to lift certain sanctions measures under the SEMA. No other instruments could be considered.

Regulatory analysis

Benefits and costs

Canadians seeking to take advantage of the General Permit are expected to be civil society organizations, non-profit organizations, charitable organizations, or individuals and groups from the Syrian diaspora in Canada. The General Permit allows specific activities and transactions that would otherwise be prohibited under the Regulations.

The General Permit lifts some restrictions for stakeholders to provide humanitarian-related aid to Syria. Therefore, the General Permit should not have any adverse impact on relevant stakeholders and is expected to have a positive impact on both Canadian organizations that will be able to undertake additional humanitarian-related activities or transactions and on the citizens of Syria who will benefit from the humanitarian support. In addition, there are no direct costs associated with the implementation of the General Permit.

Canadian banks and financial institutions are required to comply with sanctions. They will continue to do so by way of their existing monitoring systems, which may result in a minor compliance cost.

The incremental cost to the Government of Canada to implement and administer the General Permit is minimal.

Small business lens

Analysis under the small business lens concludes that the proposed General Permit will not impact Canadian small businesses. It is anticipated that primarily non-business entities and organizations would be implicated in humanitarian-related activities in Syria. Should a small business wish to participate in humanitarian-related activities in Syria, the General Permit lifts the requirement to apply for a permit under the Regulations, although the activities could be subject to any other relevant prohibitions under the Criminal Code as well as UN Security Council resolutions.

Other obligations included in the Regulations such as the duty to disclose remain in place.

One-for-one rule

The one-for-one rule does not apply, as there is no incremental change in administrative burden on stakeholders interested in benefiting from the General Permit. No regulatory titles are repealed or introduced. It is anticipated that primarily non-business entities and organizations would be implicated in humanitarian-related activities in Syria. The General Permit lifts the requirement to apply for a permit under the Regulations, though the activities could be subject to any other relevant prohibitions under the Criminal Code as well as UN Security Council resolutions.

Regulatory cooperation and alignment

The General Permit aligns Canada’s efforts with those of the U.S., the U.K., the EU, and others. While the Ministerial Order is not related to a work plan or commitment under a formal regulatory cooperation forum, they align with actions taken or announced by some of Canada’s allies, including the EU, U.K., and the U.S.

International obligations

Compliance with Canada’s international obligations was considered in the development of this proposal.

As a Member State of the United Nations and pursuant to article 25 of the United Nations Charter, Canada is legally obligated to implement binding decisions of the UN Security Council taken under Chapter VII. These decisions include measures other than the use of force (e.g. asset freeze, travel ban, arms embargoes) to maintain or restore international peace and security where a threat to the peace, breach of the peace, or act of aggression exists. Global Affairs Canada coordinates with the Department of Justice to implement these resolutions into domestic law, usually through the development of regulations under the United Nations Act (UN Act). Canada has implemented the decisions of the 1267/1989/2253 ISIL (Da’esh) and Al-Qaida Sanctions Committee of the UN Security Council by establishing the Regulations Implementing the United Nations Resolutions on the Taliban, ISIL (Da’esh) and Al-Qaida (UNAQTR). However, in the cases of the UN sanctions against HTS and JMA, Canada has implemented its international obligations through a listing as terrorist entities under the Criminal Code.

Effects on the environment

The Ministerial Order is unlikely to result in important environmental effects. In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment (SEEA Directive), a preliminary scan concluded that a SEEA 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 SEMA can nevertheless have an unintended impact on certain groups and individuals in vulnerable situations. Targeted sanctions limit the collateral effects to those dependent on listed individuals and entities and are unlikely to have a significant negative impact on vulnerable groups as compared to traditional broad-based economic sanctions directed towards a state. Furthermore, this General Permit, by lifting some restrictions to allow greater humanitarian support, is expected to have a positive impact for the citizens of Syria, including vulnerable groups.

Implementation, compliance and enforcement, and service standards

Implementation 

The Order comes into force on the day it is registered.

The names of the listed entities referenced in the General Permit will be made available online for financial institutions to review. This will help to facilitate the implementation and compliance with the Ministerial Order and the General Permit.

Compliance and enforcement

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 or the General Permit (Syria) 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.

Contact

Global Affairs Canada
Sanctions Bureau
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Email: sanctions@international.gc.ca
Telephone (toll-free): 833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085