UN Iran Sanctions Re-imposed in Canada

Summary#

These final rules amend the Regulations Implementing the United Nations Resolutions on Iran to put back in force a set of United Nations sanctions that had been lifted under the 2015 nuclear deal. They take effect on September 30, 2025 after a “snapback” was triggered when France, Germany and the United Kingdom notified the United Nations Security Council on August 28, 2025 that Iran was not meeting its commitments.

What it does#

• Rewrites and updates parts of the existing Regulations Implementing the United Nations Resolutions on Iran, including some definitions and references to international lists and guides used to identify controlled goods.
• Re-establishes export and carriage bans on goods and technology tied to nuclear fuel-cycle activities, ballistic-missile development, and other items listed in key international control documents (IAEA INFCIRC lists and related UN documents).
• Prohibits knowingly importing, buying or acquiring arms and related material from Iran.
• Prohibits carrying from Iran (by ship, air or other means) the prohibited nuclear- and missile-related items, and forbids carriers from transporting arms or related material destined for persons who acquired them from Iran.
• Prohibits providing operational services to Iranian-registered or Iranian-contracted vessels (insurance, bunkering, stevedoring, lighterage, etc.) if there are reasonable grounds to think the vessel is carrying goods whose sale or transfer is now banned. There is an exception for goods or services that are necessary for humanitarian purposes.
• Restores notification requirements to the UN committee and the International Atomic Energy Agency (IAEA) to report certain non-prohibited transfers within 10 days.
• Reinstates earlier UN asset freezes and travel restrictions on listed persons and entities; those names are incorporated into Canadian law via the UN consolidated list.
• Adjusts the rules about certificates (exemptions) and information-sharing between officials, the UN committee and the IAEA.
• Removes references to Security Council Resolution 2231 (2015) where it no longer applies after the snapback.

Who's affected#

• Businesses that export, ship or handle nuclear-related, dual‑use or missile-related goods. (Government review says current Canadian trade in these items appears limited.)
• Shipping companies, ship operators and firms providing vessel services (insurance, bunkering, stevedoring, lighterage) to Iranian-registered or Iranian-contracted vessels.
• Canadian banks and other financial institutions who must update screening and monitoring to include newly listed individuals and entities.
• The 41 individuals and 75 entities that the UN committee previously listed — they regain UN sanctions and will be listed on the UN consolidated list; this can include asset freezes and travel restrictions.
• Canadians and Canadian companies dealing with Iran who may need export permits or certificates to carry out certain activities; Global Affairs Canada administers exemptions.
• Federal agencies that enforce and administer sanctions, such as the Canada Border Services Agency (CBSA), the Royal Canadian Mounted Police (RCMP), and Global Affairs Canada.
• It is unclear how many Canadian businesses are directly affected; the government’s assessment says existing Canadian controls and past measures already covered most of these items and that trade with Iran is small (under $300 million a year).

Why it matters#

• Canada is legally required to implement binding UN Security Council decisions. These amendments bring Canadian law back in line with UN measures that were automatically reinstated after the snapback.
• In practical terms, more exports, imports, transport and vessel services involving Iran become illegal unless explicitly exempted. That can affect supply chains, shipping routes, insurance cover, and firms that work with dual‑use technologies.
• Financial institutions and businesses must update their screening and compliance systems to avoid dealing with newly listed persons and entities.
• People on the UN sanctions list will face asset freezes and travel restrictions and, under Canadian immigration rules, will be inadmissible to Canada.
• There are criminal penalties for knowingly breaking these rules, including fines up to $100,000, up to one year in jail on summary conviction, or up to 10 years in jail on indictment.