On 18 October 2023 the Governor in Council registered Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2023-220) under the Special Economic Measures Act, citing Iran's proliferation- sensitive nuclear activities and weapons-of-mass-destruction-related programme as a grave breach of international peace and security. The amendment prohibits Canadians and Canadian entities from exporting, selling or supplying to Iran dual-use goods and technology, conventional arms (battle tanks, armoured combat vehicles, large-calibre artillery, combat aircraft, attack helicopters, warships), Missile Technology Control Regime-listed equipment, and technical data related to ballistic missiles and nuclear-weapon delivery systems; it also bars importing arms and related material from Iran. The same instrument adds 156 entities and 18 individuals to Canada's Iran sanctions list (asset freeze / dealings prohibition).

Analyst notesShow

Mechanism

Amendment to the Special Economic Measures (Iran) Regulations under the Special Economic Measures Act, made by the Governor in Council on the recommendation of the Minister of Foreign Affairs. Two distinct restrictions stack in one instrument:

A trade-control layer: an export ban on dual-use items (drawn from the

regulations' technical Guide, Group 1 items 1-1.A.1 through 1-9.E and Group 2 items 2-10.c/2-10.d/2-21.b.1/2-21.b.3/2-21.b.4 — covering nuclear-related equipment and materials), conventional arms, Missile Technology Control Regime-listed equipment, and ballistic-missile/ nuclear-delivery technical data; plus an import ban on arms and related material from Iran.

A designation layer: 156 organisations and 18 individuals added to

Schedule 1, triggering an asset freeze and a Canadian-dealings prohibition — one of the larger single-instrument listing expansions in Canada's Iran sanctions programme.

Downstream implications

Canadian exporters of dual-use/controlled goods and any Canadian entity

with commercial ties to the 156 newly listed organisations must screen counterparties against the expanded Schedule 1 or face SEMA exposure.

Consistent with the broader 2023-2024 Western pattern (see also the EU's

October 2024 Iran-military-support-to-Russia listings) of using entity designations layered on top of existing dual-use export controls rather than new standalone control lists.

Open questions

Whether any of the 156 listed entities also appear on parallel US OFAC/

BIS Entity List actions from the same period — a responds_to/cross- reference candidate if a later filing establishes the overlap.

Sources

Primary: Canada Gazette, Part II, Vol. 157, No. 23 — SOR/2023-220

Secondary: Global Trade Alert — state act 81518

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Mechanism

A trade-control layer: an export ban on dual-use items (drawn from the

A designation layer: 156 organisations and 18 individuals added to

Schedule 1, triggering an asset freeze and a Canadian-dealings prohibition — one of the larger single-instrument listing expansions in Canada's Iran sanctions programme.

Downstream implications

Canadian exporters of dual-use/controlled goods and any Canadian entity

with commercial ties to the 156 newly listed organisations must screen counterparties against the expanded Schedule 1 or face SEMA exposure.

Consistent with the broader 2023-2024 Western pattern (see also the EU's

October 2024 Iran-military-support-to-Russia listings) of using entity designations layered on top of existing dual-use export controls rather than new standalone control lists.