Regulations Amending the Special Economic Measures (Iran) Regulations: SOR/2025-274

Canada Gazette, Part II, Volume 159, Number 27

Registration
SOR/2025-274 December 12, 2025

SPECIAL ECONOMIC MEASURES ACT

P.C. 2025-926 December 11, 2025

Whereas the Governor in Council is of the opinion that gross and systematic human rights violations have been committed in the Islamic Republic of Iran;

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 (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

Amendment

1 Part 2.1 of Schedule 1 to the Special Economic Measures (Iran) Regulations footnote 1 is amended by adding the following in numerical order:

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.

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Issues

The Islamic Republic of Iran continues to engage in gross and systematic human rights violations, including the violent repression of protests and its citizens, including those in custody. The human rights situation has continued to deteriorate in recent years, marked by brutal suppression of dissent, widespread abuses, and systemic discrimination, as seen in the regime’s crackdown on the “Woman, Life, Freedom” protests that began in September 2022 and again on those suspected of being engaged in espionage for alleged collaboration with Israel or the United States in the wake of the 12-day war with Israel in June 2025. International efforts, including human rights reports, resolutions, and sanctions, are meant to call attention to Iran’s human rights record and urge improvement.

Background

Human rights situation in Iran

A deep-rooted and persistent disregard for human rights has characterized the actions of the Government of Iran for decades, especially through the targeting of protesters, human rights defenders, journalists, ethnic and religious minorities, and women and girls.

Over the decades, the Government has responded to protests and dissent with widespread and brutal repression. Security forces, including the Islamic Revolutionary Guard Corps (IRGC), have used excessive and often lethal force to suppress protests. Reports from human rights organizations and United Nations (UN) experts have documented extensive violations, beatings, arbitrary arrests, and torture.

Iran’s judiciary and prison system play a central role in enabling repression. Political prisoners, including protestors, students, journalists, lawyers, and human rights defenders, are subjected to sham trials, often held behind closed doors, with verdicts based on forced confessions obtained under torture or duress. Legal representation is frequently denied or restricted, especially during pre-trial detention. Once imprisoned, detainees face solitary confinement for prolonged periods, overcrowded and unsanitary conditions, denial of medical care, psychological abuse, and physical torture.

Within the existing culture of impunity, officials and entities in Iran, such as senior officials of the IRGC and prison system, routinely, and as a matter of state policy, have a part in the gross and systematic violations of human rights of protesters, detainees, and prisoners. In this context, Iran has not demonstrated that it is taking measures to investigate human rights violations and abuses in line with international standards or to hold perpetrators accountable.

International response

Iran’s failure to uphold its international human rights obligations has been a point of condemnation by Canada and the international community. Since 2003, Canada has led the tabling of an annual UN General Assembly resolution on the situation of human rights in the Islamic Republic of Iran, working together with upwards of 40 co-sponsor states to secure broad international support. This resolution remains a key component of meaningful international engagement to call attention to the human rights situation in Iran and urge improvement.

In April 2025, the mandate of the Independent International Fact-Finding Mission on the Islamic Republic of Iran, established by the UN Human Rights Council, was expanded to thoroughly and independently monitor and investigate allegations of recent and ongoing serious human rights violations, with a particular focus on discrimination on grounds of gender, ethnicity, religion or belief, and political views. This mandate complements that of the Special Rapporteur on Iran, which monitors and reports on human rights violations in Iran.

Canada and partners, including the European Union, the United Kingdom, and the United States, have imposed multiple rounds of sanctions against Iranian officials and entities responsible for human rights violations.

Canadian sanctions against Iran

Canada established the Special Economic Measures (Iran) Regulations (“Iran Regulations”) in 2010, pursuant to the Special Economic Measures Act (SEMA). In October 2022, Canada amended the Iran Regulations to expand the scope to cover gross and systematic human rights violations, and since then has imposed 19 rounds of sanctions. In total, 206 Iranian individuals and 254 Iranian entities are now listed under the Iran Regulations. Canada also listed two (2) Iranian individuals under the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) on December 7, 2023, in relation to the torture and killing of Iranian-Canadian photojournalist Zahra Kazemi in Iran in 2003. On March 6, 2025, Canada amended the Iran Regulations again to expand the scope of the listing criteria to allow the imposition of sanctions in response to the evolving threat that Iran poses to peace and security in the region and globally, as well as designations of any current or former senior government officials, beyond senior IRGC officials. The amendments also listed individuals and entities for activities that contributed to Iran’s military support to Russia’s illegal war against Ukraine.

Objective

These amendments aim to increase pressure on Iran and send a clear signal of Canada’s condemnation of Iran’s gross and systematic violations of the rights of protesters, political prisoners, and other prisoners. They also aim to uphold Canada’s continued commitment to highlight human rights violations by Iranian authorities and urge improvement of the country’s human rights record.

Description

The amendments add four (4) individuals to Schedule 1 of the Iran Regulations for their participation in gross and systematic human rights violations in Iran given their roles in facilitating repressive policies and directing their implementation. These sanctions target senior officials who have held prominent positions within Iran’s IRGC and/or the Iranian prison system and who have played a significant role in these violations.

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 the listed individuals. These measures will also render listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act (IRPA). Under the Iran 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

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.

With respect to the amendments, public consultation would not have been appropriate given that publicizing the names of the persons targeted by sanctions could have resulted in asset flight prior to the coming into force of the amendments.

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).

Canada has established a rigorous due diligence process to consider and evaluate possible cases that may warrant the use of sanctions. Given the elements proposed in the amendments, the SEMA was identified as the instrument of choice.

Sanctions measures under the SEMA 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 sanctions in Canada. No other instrument could be considered.

Regulatory analysis

Benefits and costs

The amendments aim to impose costs on Iran for its flagrant violations of human rights domestically, and to seek to compel the regime to address the legitimate grievances and interests of its citizens.

The incremental cost to the Government of Canada to administer and enforce these additional prohibitions is minimal. The Canada Border Services Agency (CBSA), the Royal Canadian Mounted Police (RCMP), Immigration, Refugees and Citizenship Canada (IRCC), and other departments and agencies will incur a small cost to ensure their relevant systems include the persons listed through this amendment.

The amendments target specific individuals, 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. Based on initial assessment of available open-source information, it is believed that the newly listed individuals have limited linkages with Canada and therefore do not have business ties or dealings with Canadian enterprises that are significant to the Canadian economy. Therefore, it is 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 to their existing monitoring systems, which may 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. Financial institutions also have other legal obligations with respect to monitoring and reporting of relevant property ownership, export and import of goods and other activity in connection with sanctioned individuals and entities.

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 Special Economic Measures Permit Authorization Order, 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 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 individuals have limited business ties to the Canadian economy, Global Affairs Canada does not anticipate any permit application with respect to the Iran regulations.

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 Canada’s allies, such as the European Union, the United Kingdom, and the United States.

International obligations

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

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 SEEA is not required.

Gender-based analysis plus

None of the newly listed individuals have Canadian citizenship; as a result, the scope of the gender-based analysis plus is limited.

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. Rather than affecting Iran as a whole, these targeted sanctions impact individuals believed to be engaged in activities that violate human rights and present an ongoing breach of 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 those targeted individuals.

Implementation, compliance and enforcement, and service standards

The amendments 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 (IRPA), the listed individuals would be inadmissible to Canada.

The names of the listed individuals 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 Iran 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 Iran 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.

Contact

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