Regulations Amending the Special Economic Measures (Iran) Regulations: SOR/2024-44

Canada Gazette, Part II, Volume 158, Number 7

SOR/2024-44 March 7, 2024


P.C. 2024-200 March 7, 2024

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 4(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


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.


(This statement is not part of the Regulations.)


Iran continues to commit gross and systematic human rights violations, which disproportionately impact Iranian women and girls, minorities, and human rights defenders. Iranian women and girls experience targeted and intensified repression and restrictions by Iranian authorities on their fundamental rights and freedoms.


Human rights situation in Iran

Iran’s disregard for its international human rights obligations has long been the subject of condemnation by Canada and the international community. On December 19, 2023, the United Nations General Assembly (UNGA) adopted a resolution Situation of human rights in the Islamic Republic of Iran. The resolution, whose draft was introduced by Canada, condemned the intensified, targeted repression of women and girls by the Islamic Republic of Iran and expressed serious concern at the enforcement of the hijab and chastity law in Iran, including the consideration of new legislation and policy to further impose restrictive and punitive measures on women and girls.

The human rights situation in Iran continues to be deeply concerning. Particularly since 2022, the international community has witnessed the regime’s violent crackdown on dissent, as its citizens demand accountability, justice and full respect of their human rights. In September 2022, Iranian citizens began a nationwide protest under the “Woman, Life, Freedom” movement to bring attention to longstanding grievances, including the systemic discrimination of women and girls. The Iranian regime responded through intensified repressive practices, the arbitrary arrests of over 20 000 individuals for their involvement in this movement, and the sentencing of many of these individuals to the death penalty.

In 2023, the Iranian regime explored additional restrictive and punitive measures to increase limitations on the participation of women and girls in all spheres of life. These measures expanded Iran’s repressive hijab policy, which restricts the rights of women and girls who do not comply with the compulsory veiling requirements. For instance, the Iranian government is deploying cameras equipped with facial-recognition technology in public places to identify women who are ignoring Iran’s mandatory hijab law and increasing the severity of punishments for transgressions.

In addition to systemic human rights violations that target women and girls, violations of human rights in Iran also include the increasing number of executions, including of minors; systematic violations of the rule of law and the right to due process through the use of sham trials; and the discrimination, persecution, harassment, and arbitrary detention of minority ethnic and religious communities, such as the Bahá’í, and LGBTQ persons in Iran. Individuals who seek to stand up for the rights of Iranian women and girls also face harassment, intimidation, and punishment.

As the human rights situation of Iranian women and girls deteriorates, there is a need to increase pressure on the Iranian regime. Canada is therefore imposing sanctions on International Women’s Day to focus international attention on this abhorrent situation.

Canadian sanctions against Iran

Canada created the Special Economic Measures (Iran) Regulations (the Iran Regulations), pursuant to the Special Economic Measures Act (SEMA) in July 2010. The Iran Regulations were based on Canada’s view that Iran’s actions amounted to a grave breach of international peace and security that resulted or was likely to result in a serious international crisis, in particular related to Iran’s nuclear program. Canada established these new Regulations in coordination with the European Union, the United States and other like-minded partners.

The Iran Regulations have been expanded through amendments in the years since. Most recently, Canada amended the Iran Regulations in response to the rapid deterioration of human rights in Iran that started in September 2022. In October 2022, Canada amended the Iran Regulations to include circumstances of gross and systematic human rights violations. Since October 2022, Canada has imposed 15 rounds of sanctions under the Iran Regulations. On December 7, 2023, Canada also listed two Iranian individuals under the Justice for Victims of Corrupt Foreign Officials Regulations in relation to the torture and killing of Iranian-Canadian photojournalist Zahra Kazemi in Iran in 2003.


These new measures seek to maintain pressure on Iran to change its behaviour and reinforce Canada’s steadfast commitment to holding Iran to account for its actions at home and abroad. The amendments recognize the abhorrent situation of Iranian women and girls and of the individuals who defend their rights. These new measures align with similar actions taken by like-minded partners.


The amendments list two individuals for their participation in gross and systematic human rights violations in Iran given their roles to facilitate repressive policies and direct their implementation.

The newly listed individuals include Masoud Dorosti, Managing Director for the Tehran Urban and Suburban Railway Operation Company, for his enforcement of Iran’s discriminatory hijab law. In this position, the Managing Director oversees the exclusion of unveiled women from metro transportation services in Tehran. Also newly listed is Zohreh Elahian, an Iranian parliamentarian, for her support for the execution of protesters involved in the “Woman, Life, Freedom” movement that began in September 2022.

Listed individuals are subject to a broad dealings ban, effectively freezing their assets in Canada and rendering them inadmissible to Canada under the Immigration and Refugee Protection Act. Any individual or entity in Canada, and Canadians and Canadian entities outside Canada, are thereby prohibited from dealing in the property of, entering into transactions with, providing services to, or otherwise making goods available to listed persons.

Regulatory development


Global Affairs Canada regularly engages with relevant stakeholders, including civil society organizations and 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. Publicizing the names of the persons targeted by sanctions would have likely resulted in asset flight prior to the coming into force of the modifications.

Modern treaty obligations and Indigenous engagement and consultation

An initial assessment of the geographical scope of the initiative was conducted and did not identify any modern treaty obligations, as the amendments do not take effect in a modern treaty area.

Instrument choice

The Iran Regulations are the sole method to enact sanctions in Canada. No other instrument could be considered.

Regulatory analysis

Benefits and costs

Sanctions targeting specific persons 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 persons. Based on an initial assessment of available open-source information, it is believed that the newly listed individuals have limited linkages with Canada and Canadians outside Canada and, therefore, do not have business dealings that are significant to the Canadian economy. There is also limited trade between Canada and Iran, and Canada has no active trade promotion with Iran. It is therefore anticipated that there will be no significant impacts on Canadians and Canadian businesses as a result of these amendments to the Iran Regulations.

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.

Small business lens

With respect to the individuals being listed under the Iran Regulations, analysis under the small business lens concluded that the Iran Regulations will not impact Canadian small businesses. The Iran Regulations do not impose any new compliance or administrative burden on small businesses in Canada. The Iran Regulations 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 Iran Regulations, they are granted on an exceptional basis, and Global Affairs Canada does not anticipate any applications resulting from listing these individuals.

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 applications 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, including the European Union, the United Kingdom and the United States.

Strategic environmental assessment

The amendments are unlikely to result in important environmental effects. In accordance with the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals, a preliminary scan concluded that a strategic environmental assessment is not required.

Gender-based analysis plus

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 vulnerable groups and individuals.

Rather than affecting Iran as a whole, these targeted sanctions impact individuals believed to be engaged in activities that violate human rights. 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 targeted individuals and their dependents.

Furthermore, these sanctions are being introduced in support of the women of Iran who face increasingly repressive and unacceptable levels of discrimination, harassment, and persecution by the Iranian regime.

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, 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.

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.


Neil Brennan
Gulf States Relations Division
Global Affairs Canada
125 Sussex Drive
Ottawa, Ontario
K1A 0G2
Telephone: 343‑203‑5813