Iran Sanctions: Two Individuals and Two Entities

Summary#

On April 24, 2024, the federal government registered the Regulations Amending the Special Economic Measures (Iran) Regulations. The change adds two Iranian entities and two individuals to Canada’s Iran sanctions list, which bans Canadians and people in Canada from dealing with them and makes them inadmissible to Canada.

What it does#

• Adds these entities to Schedule 1:
  • Khatam al-Anbia Central Headquarters
  • Armed Forces General Staff
• Adds these individuals to Schedule 1:
  • Gholam Ali Rashid (born 1953)
  • Mohammad Reza Ashtiani (born 1960)
• People in Canada and Canadians outside Canada are prohibited from:
  • dealing in the property of listed persons,
  • entering into transactions with them,
  • providing services to them,
  • transferring property to them, or
  • otherwise making goods available to them.
• Listed people will be added to the Consolidated Canadian Autonomous Sanctions List and will be inadmissible to Canada under the Immigration and Refugee Protection Act.
• Listed people may apply to the Minister of Foreign Affairs to be removed from the list. The Minister decides whether to recommend removal.

Who's affected#

• Listed individuals and entities (the two people and two organizations named above).
• Canadians and anyone in Canada who might otherwise do business with those listed.
• Canadian banks and financial institutions, which must update monitoring systems and block dealings with listed persons.
• Canadian businesses, including small businesses, if they have any links to the listed names (the government says links appear limited).
• Enforcement and government bodies involved in sanctions and border control, including the Royal Canadian Mounted Police and the Canada Border Services Agency.

Why it matters#

• The measures cut off the listed people and groups from legal financial and commercial ties with Canada. That can freeze any assets in Canada and stop transactions through Canadian financial systems.
• The rules take effect on registration (applied before Gazette publication). The Canada Gazette entry appeared on May 8, 2024.
• Criminal penalties apply for knowingly breaking the rules: fines up to $25,000, or imprisonment for up to one year on summary conviction, or up to five years on indictment.
• The change is part of Canada’s effort to respond to Iran’s April 14, 2024 attack on Israel and to align with sanctions by allied countries. The government expects limited direct impact on most Canadians because the listed people and groups appear to have few ties to Canada.