Sanctions Expanded to Target Iranian Human Rights Abusers

Summary#

The Regulations Amending the Special Economic Measures (Iran) Regulations add a new reason for listing people and groups: participation in "gross and systematic human rights violations" in Iran. They add 9 entities and 25 individuals to Canada’s Iran sanctions list and came into force on October 3, 2022.

What it does#

• Expands the grounds for listing in the Special Economic Measures (Iran) Regulations to include people or groups who have “participated in gross and systematic human rights violations” in Iran.
• Updates who can be targeted by the rules to include:
  • associates and family members of listed people;
  • entities owned or controlled (directly or indirectly) by listed people;
  • senior officials of those entities.
• Adds the following 9 entities to the sanctions list:
  • Islamic Revolutionary Guard Corps’ (IRGC) Cyber Defense Command
  • Basij Cooperative Foundation
  • Basij Resistance Force
  • Evin Prison
  • Press TV
  • Office of the Enjoining Right and Forbidding Evil
  • Ministry of Intelligence and Security (MOIS)
  • The Morality Police
  • Qassem Soleimani Foundation
• Adds 25 individuals (senior officials, security figures, and others). Examples named in the amendments include Hassan Rouhani, Mohammad Bagher Ghalibaf, Hossein Salami, Zeinab Soleimani, and Esmail Khatib. (The full list of added names is in Schedule 1 of the Regulations.)
• The practical effect: listed persons and entities face an asset freeze in Canada and a ban on dealings — Canadians and people in Canada must not provide funds, goods, services, or enter transactions with them.

Who's affected#

• The newly listed Iranian officials and organizations.
• Canadians, people or companies in Canada, and Canadian entities abroad who might have financial or business contacts with the listed persons.
• Canadian banks and financial institutions, which must update screening and monitoring systems to block transactions involving listed parties.
• Enforcement and government bodies such as the Royal Canadian Mounted Police, the Canada Border Services Agency, and Global Affairs Canada, which handle enforcement and publishing the list.
• It is unclear from the Regulations how many Canadians (if any) have direct links to these specific newly listed people or entities; the government says links are likely limited.

Why it matters#

• These changes let Canada target people and groups it says are involved in serious human-rights abuses in Iran. The aim is to increase diplomatic and economic pressure on Iran to stop those abuses.
• In practice, the measures freeze any assets listed parties have in Canada and bar Canadians from doing business with them. That can restrict travel, bank access, and international transactions for the listed parties.
• There are criminal penalties for knowingly breaking the rules: a fine of up to $25,000 or imprisonment for up to 1 year on summary conviction, and up to 5 years if convicted on indictment.
• The amendments align Canada with actions by allies and were introduced in response to reported abuses in Iran (including the case of Mahsa Amini and the subsequent protests) and concerns about Iran’s regional activities.