Regulations Amending the Special Economic Measures (Iran) Regulations: SOR/2026-22
Canada Gazette, Part II, Volume 160, Number 4
Registration
SOR/2026-22 February 13, 2026
SPECIAL ECONOMIC MEASURES ACT
P.C. 2026-129 February 13, 2026
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 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 (1.1)footnote b, (2)footnote c and (3) of the Special Economic Measures Actfootnote d.
Regulations Amending the Special Economic Measures (Iran) Regulations
Amendment
1 Part 2 of Schedule 1 to the Special Economic Measures (Iran) Regulations footnote 1 is amended by adding the following in numerical order:
- 99 Naji Ibrahim Sharifi Zindashti
- 100 Reza Hamidiravari (also known as Reza Hamidi Ravari)
- 101 Mohammed Reza Ansari
- 102 Ali Esfanjani
- 103 Muhammed Abd Al-Razek Kanafani
- 104 Nihat Abdul Kadir Asan
- 105 Mohammed Reza Naserzadeh
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 (Iran) continues to threaten international peace and security through destabilizing activities across the Middle East and beyond. At the same time, it represses critics and human rights defenders at home and abroad. To project its influence abroad, Iran uses state bodies and proxy agents to carry out targeted acts of violence against critics of the regime and Iranian dissidents.
Background
Iran’s malign activities
Despite decades of concerted efforts by the international community, Iran continues to act as a destabilizing force across the Middle East through malign activities carried out by its own military and through its sustained support for a network of aligned non-state militias and terrorist armed groups, collectively referred to as the “Axis of Resistance.” Iran’s backing of Axis members, such as Hamas, Hezbollah, and the Houthis, which Canada has designated as terrorist entities or sanctioned, includes financial assistance, arms provision, technology transfers, training, and ideological and political support, contributing significantly to regional instability and insecurity. Within its borders, Iran also engages in the repression of dissidents and human rights defenders through threats, violence, surveillance, and arbitrary arrests. Beyond its borders, Iran engages in so-called “transnational repression” to target perceived opponents abroad.
Transnational repression
Iran conducts destabilizing activities abroad through state bodies, including the Islamic Revolutionary Guard Corps (IRGC) and the Ministry of Intelligence and Security (MOIS). Under the direction of state bodies, Iran uses proxy agents and transnational organized crime networks to silence, intimidate, harass, and, in some cases, kill Iranian dissidents, human rights defenders, and perceived regime opponents. These tactics include surveillance, arbitrary detention, threats against family members, disinformation campaigns, and the use of legal or physical force to target critics both inside and outside Iran. These operations are coordinated at times using diplomatic and legal channels, and persistent digital surveillance of diaspora communities. Such actions contribute to the undermining of international peace, security, and stability and advance the policies of the Iranian regime.
International response
Transnational repression by Iran has been widely condemned by the international community. Western intelligence agencies have reported an increase in Iranian threats worldwide, including foiled plots in Canada, such as the attempted 2024 assassination of former Justice Minister Irwin Cotler. On June 17, 2025, G7 leaders released a statement on transnational repression, condemning it, defining it, and outlining actions to counter it. On July 31, 2025, Canada joined the United Kingdom-led statement, along with 13 other countries, on Iranian State Threat Activity in Europe and North America, condemning the growing number of state threats from Iranian intelligence services in their respective territories. On September 12, 2025, Canada and other members and associate members of the G7 Rapid Response Mechanism (RRM) issued the Statement on Iranian Transnational Repression and Other Malign Activities. On November 23, 2025, G7 Interior and Security Ministers reaffirmed G7 condemnation of transnational repression and launched a Digital Transnational Repression Detection Academy under the G7 RRM to build technical capacity to detect and collectively respond to transnational repression threats in the digital space.
Since 2024, the European Union, the United Kingdom, and the United States have imposed sanctions against individuals who, at the direction of the Iranian regime, participated in and were responsible for the facilitation of transnational repression efforts that targeted for assassination Iranian dissidents and opposition activists.
Canadian sanctions against Iran
Canada established the Special Economic Measures (Iran) Regulations (the “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 20 rounds of sanctions. In total, 210 Iranian individuals and 254 entities are now listed under the Iran Regulations. On March 6, 2025, Canada further amended the Iran Regulations to broaden the listing criteria, enabling the imposition of sanctions in response to Iran’s evolving threat to regional and global peace and security, and to include current or former senior government officials, beyond senior IRGC officials. These amendments also listed individuals and entities for activities that contributed to Iran’s military support to Russia’s illegal war against Ukraine. Canada also listed two Iranian individuals under the Justice for Victims of Corrupt Foreign Officials Act (JVCFOA) on December 7, 2023, in relation to the 2003 torture and killing in Iran of Zahra Kazemi, an Iranian-Canadian photojournalist and activist.
Objective
These amendments aim to increase pressure on Iran and to send a clear message of
- Canada’s condemnation of acts of repression and transnational repression perpetrated by Iranian state bodies or their proxies, which constitutes a grave breach of international peace and security; and
- Canada’s continued commitment, along with its allies, to countering Iran’s regional and global malign influence and destabilizing activities.
Description
The amendments add to Schedule 1 of the Iran Regulations seven individuals linked to transnational organized crime networks and engaged in state-directed activities of destabilization intended to undermine international peace, security, or stability in a manner consistent with the policies of Iran. Among the listed individuals, there are prominent figures related to the “Zindashti” crime network, including one senior official of Iran’s IRGC and one intelligence officer of its MOIS.
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 these amendments, public consultation would not have been appropriate given that publicizing the names of the persons targeted by sanctions would have likely 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, SEMA, and the JVCFOA.
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, SEMA was identified as the instrument of choice.
Sanctions measures under SEMA are imposed by the Governor in Council, on the recommendation of the Minister of Foreign Affairs, through a regulatory process. Regulations are the only option to enact sanctions in Canada. No other instruments could be considered.
Regulatory analysis
Benefits and costs
The incremental cost to the Government of Canada to administer and enforce these additional sanctions measures is minimal. The Canada Border Services Agency, the Royal Canadian Mounted Police, Immigration, Refugees and Citizenship Canada, and other departments and agencies will bear a small cost to ensure their relevant systems include the persons listed through these amendments.
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 an 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 dealings that are significant to the Canadian economy. As such, 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 and entities 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 the monitoring and reporting of relevant property ownership, export and import of goods, and other activities in connection with sanctioned individuals and entities.
Small business lens
Analysis under the small business lens concludes that the amendments will have minimal impact on Canadian small businesses. The amendments listing new individuals and entities do not impose any new compliance or administrative burden on small businesses in Canada. These amendments prohibit Canadian businesses from dealing with, providing services to, or otherwise making goods available to listed persons, but do not create obligations related to them. While Canadian businesses may seek permits under the Special Economic Measures Permit Authorization Order, 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 Special Economic Measures Permit Authorization Order 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 amendments.
Regulatory cooperation and alignment
While the amendments are not related to a work plan or a commitment under a formal regulatory cooperation forum, they align with actions taken by Canada’s allies and partners, 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 and entities believed to be engaged in activities that present an ongoing breach of international peace and security. Therefore, these targeted sanctions limit the collateral effects to those dependent on listed individuals and entities and are not expected to have a significant impact on vulnerable groups, unlike traditional broad-based economic sanctions directed toward a state.
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 IRPA, the listed individuals are rendered 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 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 Iran 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 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 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 0G2
Email: sanctions@international.gc.ca
Telephone (toll-free): 1‑833‑352‑0769
Telephone (local): 343‑203‑3975
Fax: 1‑613‑995‑9085