Canada: Sanctions Update: Canada's Ban On Trade With Iran

In its most recent sanctions measures, Canada has imposed a nearly complete ban on imports from and exports to Iran, including restrictions on the provision of certain services to individuals and businesses in Iran. The recent measures, announced on May 29, 2013, follow a steady increase in Canada's sanctions against Iran under the Special Economic Measures Act (SEMA) in recent years. In a statement made on May 29, 2013, Foreign Affairs Minister John Baird attributed the need for further sanctions to an absence of progress, stating that in "round after round of talks with both the International Atomic Energy Agency and the P5+1 [the five permanent members of the UN Security Council and Germany], Iran has failed to engage meaningfully while the risk posed by its enrichment activities only increases." The impact of these new measures should be reviewed by all Canadian persons and entities involved in trade with Iran.

Sanctions Under SEMA

SEMA enables Canada to impose sanctions by enacting orders or regulations in two situations:

  • For the purpose of implementing a decision, resolution or recommendation of an international organization of states or association of states, of which Canada is a member, that calls on its members to take economic measures against a foreign state, or
  • Where the federal Cabinet is of the opinion that a grave breach of international peace and security has occurred that has resulted or is likely to result in a serious international crisis

In recent years, SEMA has been used to implement Canadian sanctions against several countries, including Burma, Libya, North Korea, Syria, and Zimbabwe.

Canada's Existing Sanctions Against Iran

The United Nations Security Council has imposed various rounds of sanctions against Iran, which have been implemented in Canada pursuant to the United Nations Act. In addition to the UN sanctions (and in co-ordination with other states), Canada first imposed its own sanctions on trade with Iran under SEMA in 2010. The existing sanctions under SEMA prohibit:

  • Dealing with designated individuals and entities listed in the Special Economic Measures (Iran) Regulations (the Designated Persons List)
  • Exporting or otherwise providing to Iran arms and related materials; items that could contribute to Iran's nuclear proliferation activities; and items used in refining oil and gas (Prohibited Goods)
  • Providing technical data related to Prohibited Goods
  • Making any new investment in the Iranian oil and gas sector, or providing or acquiring financial services for this purpose
  • Providing or acquiring financial services to allow an Iranian financial institution to be established in Canada (including a branch, subsidiary or office), or providing or acquiring financial services to allow a Canadian financial institution to be established in Iran
  • Establishing banking relationships with Iranian financial institutions, or purchasing any debt from the Government of Iran
  • Providing services for the operation or maintenance of a vessel owned or controlled by, or operating on behalf of, the Islamic Republic of Iran Shipping Lines

Canada has gradually enhanced its sanctions in tandem with other international efforts. Additions to the sanctions in 2011 and 2012 included:

  • A prohibition on virtually all financial transactions with Iran, subject to limited exceptions
  • The expansion of the list of Prohibited Goods to include all items that could be used in Iran's nuclear program; goods used in the shipbuilding, mineral exploration, mining, metal production and telecommunications industries; vessels designed to transport or store crude oil or its products; and hard currency totalling more than C$40,000
  • The addition of new individuals and entities to the Designated Persons List

May 29, 2013 Measures

Significant changes imposed by the latest amendments to Canada's Special Economic Measures (Iran) Regulations (the Regulations) include:

  • A general prohibition, subject to limited exceptions (mostly humanitarian), on exports to and imports from Iran
  • A prohibition on Canadian investment in an entity in Iran
  • Several additions to the Designated Persons List

General prohibition on trade. The Regulations now prohibit, subject to certain enumerated exceptions, the export, sale, supply, or shipping of all goods to Iran, to a person in Iran, or to a person for the purposes of a business carried on in or operated from Iran. Previously, this prohibition applied only to specific types of goods. It also now extends to prohibit the provision of goods "to a person for the purposes of a business carried on in or operated from Iran". Similarly, the Regulations now prohibit any person in Canada and any Canadian outside Canada from importing, purchasing, acquiring, or shipping any goods that are exported, supplied, or shipped from Iran after May 29, 2013, subject to certain enumerated exceptions.

The prohibition also applies to prevent the provision to Iran of certain technical data (mostly relating to the petrochemical industry) as well as the provision of marketing, financial and other services related to that industry.

Prohibition on investment. The Regulations now prohibit any Canadian investment in an entity in Iran. Previously, this section prohibited Canadian investment in certain entities in Iran engaged in the oil or natural gas industry, as well as the Canadian provision or acquisition of services for the purpose of investing in the oil or natural gas industry in Iran.

Addition of designated persons. The latest amendments to the Regulations add a substantial number of names to the Designated Persons List. The Regulations prohibit a broad range of dealings with designated persons and impose disclosure obligations on all Canadians relating to property owned or controlled by or on behalf of designated persons. Additionally, certain entities are required to determine on a continuing basis whether they are in possession or control of property owned or controlled by or on behalf of a designated person.

Implications for Canadian Businesses

It appears that the sanctions are having an increasingly significant effect on both the Iranian economy and those who trade with Iran. As discussed above, previously Canada's sanctions were limited to financial services and certain industry sectors as well as nuclear and military activities. The most recent changes impose a broad-based prohibition on Canadian trade with and investment in Iran. These are significant changes that impact all industries involved in economic activity with Iran. Companies engaged in such activity should review the new measures and the amended Designated Persons List immediately.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Events from this Firm
23 Nov 2018, Other, Toronto, Canada

Cybersecurity, including data privacy and security obligations, has become a critical chapter in every company’s risk management playbook.

28 Nov 2018, Speaking Engagement, Toronto, Canada

Arbitration has a number of advantages and some disadvantages for the resolution of domestic and international commercial disputes.

Similar Articles
Relevancy Powered by MondaqAI
Blake, Cassels & Graydon LLP
In association with
Related Topics
Similar Articles
Relevancy Powered by MondaqAI
Blake, Cassels & Graydon LLP
Related Articles
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions