Regulations Amending the Regulations Implementing the United Nations Resolutions on Iran: SOR/2025-202

Canada Gazette, Part II, Volume 159, Number 22

Registration
SOR/2025-202 September 30, 2025

UNITED NATIONS ACT

P.C. 2025-696 September 30, 2025

Whereas the Security Council of the United Nations, acting under Article 41 of the Charter of the United Nations, adopted Resolution 2231 (2015) on July 20, 2015;

And whereas it appears to the Governor in Council to be necessary to make regulations for enabling the measures set out in paragraph 12 of that resolution to be effectively applied;

Therefore, Her Excellency the Governor General in Council, on the recommendation of the Minister of Foreign Affairs, makes the annexed Regulations Amending the Regulations Implementing the United Nations Resolutions on Iran under section 2 of the United Nations Act footnote a.

Regulations Amending the Regulations Implementing the United Nations Resolutions on Iran

Amendments

1 (1) The definitions Joint Commission, Joint Comprehensive Plan of Action and Security Council Resolution 2231 in section 1 of the Regulations Implementing the United Nations Resolutions on Iran footnote 1 are repealed.

(2) The definition designated person in section 1 of the Regulations is replaced by the following:

designated person
means a person
  • (a) whose name appears on the Annex to Security Council Resolution 1737;
  • (b) that is designated by the Security Council under paragraph 10 or 12 of Security Council Resolution 1737 as being engaged in, directly associated with or providing support for Iran’s proliferation sensitive nuclear activities or the development of nuclear weapon delivery systems; or
  • (c) that is designated by the Committee of the Security Council under subparagraph 18(f) of Security Council Resolution 1737 as being engaged in, directly associated with or providing support for Iran’s proliferation sensitive nuclear activities or the development of nuclear weapon delivery systems. (personne dĂ©signĂ©e)

(3) Section 1 of the Regulations is amended by adding the following in alphabetical order:

Committee of the Security Council
means the Committee of the Security Council established under paragraph 18 of Security Council Resolution 1737. (ComitĂ© du Conseil de sĂ©curitĂ©)

2 (1) Paragraphs 4(1)(a) to (c) of the Regulations are replaced by the following:

(2) The Regulations are amended by replacing “Information Circular INFCIRC/254/Rev.12/Part 1” with “Part 1 of the International Atomic Energy Agency Information Circular INFCIRC/254, as amended from time to time,” in the following provisions:

3 The Regulations are amended by adding the following after section 4:

Arms and related material

5 It is prohibited for any person in Canada or any Canadian outside Canada to knowingly import, purchase or acquire arms and related material, wherever situated, from Iran, from any person in Iran or from any other person acting on behalf of or at the direction of Iran or any person in Iran.

4 Section 6 of the Regulations is renumbered as subsection 6(1) and is amended by adding the following:

Products referred to in paragraphs 4(1)(a), (b) and (e)

(2) It is prohibited for an owner, master or operator referred to in subsection (1) to carry, cause to be carried or permit to be carried from Iran, directly or indirectly, any of the products referred to in paragraphs 4(1)(a), (b) and (e).

Arms and related material to Canada

(3) It is prohibited for an owner, master or operator referred to in subsection (1) to carry, cause to be carried or permit to be carried arms and related material, wherever situated, that are destined for any person in Canada that acquired them from Iran, from any person in Iran or from any person acting on behalf of or at the direction of Iran or any person in Iran.

5 The Regulations are amended by adding the following after section 6:

Iranian vessels

6.1 (1) It is prohibited for any person in Canada or any person outside Canada to knowingly provide a vessel that is registered in Iran or that is contracted to Iran or any person in Iran with goods, materials or services for the vessel’s operation or maintenance, including in respect of insurance, stevedoring, bunkering and lighterage, if there are reasonable grounds to believe that the vessel is carrying products the sale, supply or transfer of which is prohibited by section 4.

Exception — humanitarian purposes

(2) Subsection (1) does not apply if the goods, materials or services are necessary for humanitarian purposes.

6 (1) Subsection 10(1) of the English version of the Regulations is replaced by the following:

Exemption

10 (1) A person that wishes to do an activity that is prohibited under these Regulations may, before doing the activity, apply to the Minister in writing for a certificate to exempt the activity from the application of the Regulations.

(2) Subsection 10(2) of the Regulations is replaced by the following:

Certificate

(2) The Minister must issue the certificate if the Security Council did not intend that such an activity be prohibited or if the Security Council or the Committee of the Security Council has approved the activity in advance.

7 (1) Paragraphs 11(1)(b) and (c) of the Regulations are repealed.

(2) The portion of subsection 11(2) of the Regulations before paragraph (a) is replaced by the following:

Certificate — paragraph (1)(a)

(2) If it is established in accordance with Security Council Resolution 1737 that the property is necessary for basic or extraordinary expenses or is subject to a lien, mortgage or security interest, to a hypothec or prior claim, to a charge or to a judicial, administrative or arbitral decision, the Minister must issue a certificate within the following timelines:

(3) Subsection 11(3) of the Regulations is repealed.

8 The Regulations are amended by adding the following after section 11:

Minister must notify

11.1 The Minister must notify the Committee of the Security Council and the International Atomic Energy Agency within 10 days after the supply, sale or transfer of products

9 Section 14 of the Regulations is replaced by the following:

Disclosure by official

14 (1) An official may, for the purpose of responding to a request from the Security Council or the Focal Point for De-listing, disclose personal information to the Minister.

Disclosure by Minister

(2) The Minister may, for the purpose of administering or enforcing these Regulations or fulfilling an obligation under a resolution of the Security Council, disclose personal information to the Security Council or the Focal Point for De-listing.

Application Before Publication

10 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

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

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

As a member of the United Nations (UN) and pursuant to article 25 of the United Nations Charter (the UN Charter), Canada is legally obligated to implement binding decisions of the United Nations Security Council (UNSC) taken under Chapter VII (i.e. decisions and actions with respect to threats to peace, breaches of the peace, and acts of aggression). These decisions include measures other than the use of force (e.g. sanctions, arms embargoes) to maintain or restore international peace and security where a threat to peace, breach of the peace, or act of aggression exists.

Following France, Germany and the United Kingdom (the E3) informing the UNSC on August 28, 2025, of Iran’s non-compliance with its obligations related to nuclear non-proliferation as per the Joint Comprehensive Plan of Action (JCPOA), previously terminated UN sanctions on Iran re-entered into force, as agreed upon in the JCPOA. As a result, Canada is amending the Regulations Implementing the United Nations Resolutions on Iran (the UN Iran Regulations) to implement the UNSC decision into domestic law.

Background

In 2003, the International Atomic Energy Agency (IAEA) confirmed the existence of previously undeclared nuclear facilities in Iran, contrary to Iran’s Safeguards Agreement pursuant to the Treaty on the Non-Proliferation of Nuclear Weapons (NPT). Iran refused to suspend proliferation-sensitive activities and, in February 2006, the IAEA Board of Governors reported to the UNSC that Iran’s nuclear program raised questions within the competence of the Security Council. In response, the UNSC imposed a series of increasingly strict sanctions measures between December 2006 and June 2010 [UNSC resolutions 1737 (2006), 1747 (2007), 1803 (2008) and 1929 (2010)], aimed at curtailing Iran’s growing nuclear capacity.

In 2007, Canada established the UN Iran Regulations to implement the decisions of the UNSC related to sanctions against Iran.

On July 14, 2015, the five permanent members of the UNSC (China, France, Russia, the United Kingdom and the United States) and Germany reached an agreement with Iran, i.e. the JCPOA. Under the JCPOA, Iran accepted long-term restrictions on its nuclear program, combined with extensive international verification, aimed at preventing Iran from being able to produce a nuclear weapon. On July 20, 2015, the Security Council endorsed the JCPOA by adopting resolution 2231 (2015). In return, Iran received significant relief from sanctions imposed by the UNSC for its past non-compliance with international obligations in regard to its nuclear program.

In 2016, Canada amended its autonomous sanctions against Iran under the Special Economic Measures (Iran) Regulations (SEMA Iran Regulations) to recognize progress made under the JCPOA. However, Canada continued to have serious concerns about Iran’s nuclear ambitions, and, consequently, maintained tight restrictions on sensitive goods related to nuclear proliferation and the development of Iran’s ballistic missile program. In October 2023, Canada again amended its autonomous sanctions against Iran to roll over UN sanctions measures that expired on October 18, 2023, pursuant to resolution 2231.

In 2018, under the first Trump administration, the United States withdrew from the JCPOA. Starting in 2019, Iran responded by incrementally reducing its compliance with the JCPOA, including by expanding enrichment activities and increasing quantities of highly enriched uranium. Efforts to negotiate continued between Iran, the United States and other partners to achieve a mutual return to the JCPOA. However, on July 2, 2025, Iran announced that it would suspend cooperation with the IAEA.

The JCPOA and UNSC Resolution 2231 (2015) include a “snapback” mechanism that allows for the automatic reimposition of UN sanctions on Iran if it is found to be in significant non-compliance with the agreement. Any of the parties to the JCPOA can notify the UNSC of such an issue. Within 30 days of the notification, all UN sanctions on Iran previously terminated upon adoption of the JCPOA are automatically reinstated. This mechanism was designed to ensure that Iran could not violate the nuclear agreement without facing swift and decisive consequences, even if some Council members disagreed.

On August 28, 2025, the E3 informed the UNSC of what they believe to be Iran’s significant non-performance of its commitments under the JCPOA, thereby triggering the “snapback” mechanism.

Objective

These non-discretionary amendments to the UN Iran Regulations aim to fulfill Canada’s international obligations and give effect to the decisions of the UNSC to reimpose sanctions measures related to Iran’s nuclear and ballistic missile programs, as outlined in UNSC resolutions 1737 (2006), 1747 (2007), 1803 (2008) and 1929 (2010).

Since 2019, Iran has not complied with commitments set out in the JCPOA, with serious implications for regional and international security: Iran exceeded limits agreed upon in the JCPOA on enriched uranium, heavy water and centrifuges; Iran restricted the IAEA’s ability to conduct JCPOA verification and monitoring activities and has abandoned the implementation and the ratification process of the Additional Protocol to its Comprehensive Safeguards Agreement. These actions directly increase Iran’s capacity to progress toward developing a nuclear weapon. Re-establishing previously terminated UNSC sanctions on Iran serves to address the threat posed by Iran’s nuclear, ballistic missile, and conventional arms programs.

Description

Canada is amending the UN Iran Regulations to prohibit persons in Canada and Canadians abroad from

For existing prohibitions, references to IAEA and UNSC documents will be amended to ensure they reflect the latest version available.

The UN Iran Regulations will also be amended to reimpose the following notifications for countries exporting certain non-prohibited nuclear-related items to Iran, in particular

To reflect that UNSC Resolution 2231 (2015) ceases to apply 30 days after “snapback” is triggered, the UN Iran Regulations will be amended to repeal mentions of this resolution.

All references to INFCIRCs in the amendments are updated in a manner that ensures any future updates are incorporated by reference.

Any asset freezes and travel bans originally imposed by the 1737 Committee on 41 individuals and 75 entities will re-enter into force due to “snapback.” The names of designated individuals and entities are incorporated into Canadian law automatically via reference. The names can be found on the United Nations Security Council Consolidated List.

Regulatory development

Consultation

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

As a member of the UN, Canada is obligated to implement the measures included in UNSC resolutions pursuant to Chapter VII of the UN Charter. With respect to the amendments, no external outreach was conducted.

Indigenous engagement, consultation and modern treaty obligations

In accordance with the Cabinet Directive on the Federal Approach to Modern Treaty Implementation, an analysis was undertaken to determine whether the amendments are likely to give rise to modern treaty obligations. The assessment examined the geographic scope and subject matter of the amendments in relation to modern treaties in effect and no modern treaty obligations were identified.

Instrument choice

The imposition of sanctions against foreign states and non-state actors is a key tool for the international community to support peace and security and enforce international norms and laws. The Parliament of Canada has enacted legislation authorizing the imposition of sanctions through the United Nations Act (UNA), the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law).

Sanctions measures under the UNA are imposed by the Governor in Council, on the recommendation of the Minister of Foreign Affairs, through a regulatory process. Regulations are the sole method of enacting UNSC resolutions related to sanctions in Canada. No other instrument could be considered.

Regulatory analysis

Benefits and costs

The amendments make Canada compliant with its obligations under the United Nations Charter by implementing the measures outlined in UNSC resolutions 1737 (2006), 1747 (2007), 1803 (2008) and 1929 (2010).

No significant impacts on Canadian businesses are anticipated as a result of the amendments. Overall, Canadian trade (import and export) with Iran amounts to less than $300 million annuallyfootnote 2 and is mainly (over 90%) in the market of agricultural goods. The majority of the activities affected by the amendments are already either prohibited under Canada’s autonomous SEMA regime against Iran, or controlled under the Export and Import Permits Act (EIPA).

All goods, materials and technology whose export to Iran will be prohibited under the amendments are already included in Canada’s Export Control List. Therefore, exporting these goods would already require seeking an export permit. Since July 2023, there have been no applications for export permits for goods that would be impacted by the amendments.

The export of several nuclear, dual-use, and ballistic missile-related goods is already prohibited under both the SEMA and the UNA Iran Regulations.

A comprehensive arms embargo is also already in place under the SEMA Iran Regulations.

There are two groups of activities not already captured under another Canadian regulatory regime:

However, GAC has assessed that no Canadian company is currently importing or transporting such goods from Iran. Open-source information does not suggest that Canadian companies are currently involved in providing such services to Iranian-owned or contracted vessels, but GAC is unable to confirm this with certainty due to a lack of data.

Sanctions targeting specific persons have less impact on Canadian businesses than traditional broad-based economic sanctions. Based on an initial assessment of available open-source information, it is believed that the individuals and entities listed by the UNSC have limited linkages with Canada. Therefore, it is anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of the updates to the UN sanctions list.

Canadian businesses may seek certificates under the UN Iran Regulations to allow them to engage in an activity otherwise prohibited by those regulations. Those certificates are granted on an exceptional basis. However, GAC does not anticipate any applications resulting from these amendments, as the GAC’s assessment has not identified business dealings that are significant to Canada’s economy.

Canadian businesses are also subject to the duty to disclose under the UN Iran Regulations, which would represent a direct compliance requirement. However, as the newly listed persons have no known legitimate linkages with Canada, GAC does not anticipate any disclosures resulting from the amendments.

The incremental cost to the Government of Canada to administer and enforce these amendments will be minimal. Given that the Canada Border Services Agency (CBSA) currently enforces prohibitions and controls related to exports of goods from Canada to Iran under the SEMA Iran Regulations and the Export Control List, and that these prohibitions and controls are substantially similar to the prohibitions under the UN Iran Regulations, the incremental resource impacts of the “snapback” on the CBSA are not expected to be significant. The Royal Canadian Mounted Police (RCMP), Immigration, Refugees and Citizenship Canada, and other departments and agencies may incur a small cost to update their relevant systems to include the persons listed through this amendment.

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 will also result in a minor compliance cost. As of August 2024, financial institutions must report transactions suspected of being related to sanctions evasion to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Further, the Minister of Finance has also issued a directive flagging all transactions originating from, or bound for, Iran as high risk, triggering the implementation of enhanced due diligence measures. Financial institutions also have other legal obligations with respect to the monitoring and reporting of relevant property ownership, export and import of goods, and other activities in connection with sanctioned individuals and entities. Given the measures already in place, any costs are expected to be incremental over the long-term.

Small business lens

As an initial assessment confirms that, because of existing prohibitions and restrictions in place under the SEMA Iran Regulations and the Export Control List, it is unlikely that any Canadian businesses, including small businesses, are currently engaging in activities that will be prohibited by these amendments. Therefore, no impact on small businesses is expected.

One-for-one rule

The amendments will reimpose prohibitions on trade in certain goods and technology with Iran. As noted above, Canadian businesses may seek certificates under the UN Iran Regulations to allow them to engage in such trade in exceptional cases. The certificate process for businesses meets the definition of “administrative burden” in the Red Tape Reduction Act. Therefore, there could be an incremental increase in administrative burden for any business that seeks such a certificate. However, the amendments implement a non-discretionary obligation (under the UNA) and are, therefore, exempt from the requirement to offset administrative burden and regulatory titles under the one-for-one rule.

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 UNSC resolutions 1737 (2006), 1747 (2007), 1803 (2008), and 1929 (2010) and are made to fulfill Canada’s obligation to implement all measures taken by the UNSC under Chapter VII of the UN Charter. These resolutions were implemented into Canadian law until the adoption of Resolution 2231 (2015), which provided sanctions relief to Iran.

International obligations

Compliance with Canada’s international commitments was considered in the development of these amendments.

Effects on the environment

The amendments are 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 strategic environmental and economic assessment is not required.

Gender-based analysis plus

The subject of sanctions has previously been addressed for effects on gender and diversity. Although sanctions are intended to facilitate change to restore peace and security, protect and advance human rights, and combat foreign corruption through economic pressure on states and responsible individuals, they can nevertheless have an impact on vulnerable groups and individuals. In countries facing sanctions, such groups have historically been more likely to bear the political and economic instability caused by economic sanctions due to their disadvantaged position in society.

Implementation, compliance and enforcement, and service standards

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

Consequential to being designated by the 1737 Committee, and pursuant to the application of paragraph 35.1(a) of the Immigration and Refugee Protection Act, the designated 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 United Nations Security Council Consolidated List. This will help persons in Canada and Canadians outside of Canada to comply with the Regulations.

Pursuant to section 10 of the UN Iran Regulations, the Sanctions Bureau of GAC administers applications for certificates. Certificates may be granted in exceptional circumstances on a case-by-case basis and at the discretion of the Minister of Foreign Affairs. Pursuant to the UN Iran Regulations, the Minister must issue a certificate if the Security Council did not intend that an activity be prohibited, or if the Security Council has approved the activity in advance.

As the amendments target a number of prohibited items which are already included in Canada’s Export Control List, an export permit pursuant to the Export and Import Permits Act is also required for the items to be exported lawfully to Iran. Applications for export permits are administered by the Strategic Export Controls Bureau of GAC.

The Trade Commissioner Service at Global Affairs Canada, abroad and in 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. Global Affairs Canada is also increasing outreach efforts across Canada — including to engage with businesses, universities, and provincial/territorial governments — to enhance national awareness of and compliance with Canadian sanctions.

Canada’s sanctions regulations are enforced by the RCMP and the CBSA. In accordance with section 3 of the UNA, every person who knowingly contravenes or fails to comply with the regulations is liable upon summary conviction to a fine of not more than $100,000 or to imprisonment for a term of not more than one year or to both, and upon conviction on indictment to imprisonment for a term of not more than 10 years.

GAC collaborates with the CBSA on effective enforcement, activating a border lookout when a new prohibition is implemented and providing assessments on whether sanctions are engaged, as requested. The CBSA possesses the essential on-the-ground presence, expertise, and authorities for enforcement.

Contact

Global Affairs Canada
Sanctions Bureau
125 Sussex Drive
Ottawa, Ontario
Canada
K1A 0G2
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 613‑995‑9085
Email: sanctions@international.gc.ca