In this post we describe the economic sanctions imposed by Canada since our October 5, 2022 update. While the latest sanctions on Russia, Belarus and Iran are largely incremental extensions of existing measures, a new sanctions regime has been imposed in response to the anarchic violence in Haiti. Greater enforcement against sanctions violators by the Canadian government is anticipated.


Domestic human rights violations and the provision of drones used by Russia in Ukraine prompted the Canadian government to amend the Special Economic Measures (Iran) Regulations to impose a number of new sanctions:

  • On October 11, 2022, 17 individuals, many of whom are or were Iranian government officials, and three entities were listed for that participation in or enabling gross human rights violations, including against Iranian women, or perpetuating disinformation activities to justify the Iranian regime's repression and persecution of its citizens.
  • On October 19, 2022, six individuals and four entities were listed for similar reasons. The entities include Iranian governmental bodies such as the Guardian Council, the Assembly of Experts, and the Expediency Discernment Council.
  • On October 28, 2022, four individuals and two entities were listed, including senior officials and prominent regime supporters, on the basis that the Canadian government has reason to believe that:
    • they have participated in gross and systematic human rights violations either in Iran or in the regime's malign activities abroad, including by attacking other states; or
    • they have participated in the Iranian regime's unjust and systematic persecution of Iran's Baha'i religious minority.
  • On November 16, 2022, six individuals and two entities were listed being senior officials, prominent regime supporters and entities that Canada believes have participated in gross and systematic human rights violations in Iran, including brutal crackdowns on protesters and in the regime's malign activities abroad. Canada stated that the two listed entities are key to the regime's ongoing activities aimed at destabilizing international peace and security, including through the sale of weapons and the provision of Iranian military personnel to train and assist Russian forces on the use of Iranian drones.

In short, most of the designations relate to the Iranian state's domestic activities but have recently been expanded to encompass sanctions related to Iran's supply of drones to Russia that have been used against Ukraine. This is in part related to a rapidly changing global security environment in which Iran is apparently allying itself with Russia at least insofar as Russia's war in Ukraine is concerned.


In response to the ongoing war in Ukraine and also to the repression of domestic political dissent, several further rounds of sanctions have been imposed on Russia by way of amendments to the Special Economic Measures (Russia) Regulations:

  • On October 14, 2022, 34 individuals and one entity were listed on the basis that Canada believes they are agents of Russian propaganda or their family members, or influential individuals spreading disinformation.
  • On October 28, 2022, six entities involved in the energy sector were listed, along with 35 individuals who are senior executives of sanctioned energy entities.
  • On November 10, 2022, 23 individuals were listed by virtue of their roles in the Russian justice and security sector. These include police officers and investigators, prosecutors, judges and prison officials, including senior Russian government officials who Canada believes have been involved in gross and systematic human rights violations in Russia against opposition leaders such as the currently-jailed Vladimir Kara-Murza and Alexey Navalny.

As the war in Ukraine continues, it seems likely that there will be further listings of Russian persons.


On November 17, 2022, Canada amended the Special Economic Measures (Belarus) Regulations to add 22 Belarusian officials including those determined to be complicit in stationing and transporting Russian military personnel and equipment involved in the invasion of Ukraine and the attempted annexation of Ukrainian territory as well as 16 Belarusian companies involved in military manufacturing, technology, engineering, banking and railway transportation. Canada stated that it anticipated that these measures would exert further pressure on the Belarusian leadership and called for President Lukashenko to cease being an instrument of the Russian regime.


Canada implemented a sanctions program in respect of Haiti in response to the ongoing Haitian humanitarian crisis related to armed gangs using the termination of a fuel subsidy to escalate civil unrest and atrocities perpetuated against Haitians, particularly women and girls, on a daily basis.

  • On November 3, 2022, Canada enacted the new Special Economic Measures (Haiti) Regulations, which established the usual prohibited dealing regime and listed two individuals (one a current and one a former Haitian senator) who are members of the political elites, in response to the egregious conduct of political elites who provide illicit financial support to armed gangs.
  • On November 10, 2022, Canada enacted the new Regulations Implementing the United Nations Resolution on Haiti, made under the authority of the United Nations Act, which provides a mechanism to implement into Canadian domestic law sanctions regimes developed by committees of the United Nations Security Council. Among other things, this established the usual prohibited dealing regime for individuals and entities who are anticipated to be identified by a UNSC Committee as having engaged in or supported criminal activities and violence involving armed groups and criminal networks that promote violence including the forcible recruitment of children by groups and networks, kidnappings, trafficking in persons and the smuggling of migrants, and homicides and sexual and gender-based violence.
  • On November 17, 2022, the Special Economic Measures (Haiti) Regulations were amended to add six individuals, thus making them subject to the general dealing prohibition, on the basis that they are members of the Haitian political elite who use their position and influence to support criminal armed gangs spreading terror and violence in Haiti.

The Haitian sanctions imposed by Canada highlight a trend of imposing sanctions on the basis of serious human rights violations. Stay tuned for such sanctions in relation to other jurisdictions as Canada is likely to continue to be called on to not overlook allegations of serious human rights violations in other countries.

Looking Ahead: More Sanctions, More Enforcement

Another month, further rounds of Canadian economic sanctions. Given the deteriorating state of international relations, widespread human rights violations and Canada's ongoing albeit slow motion pivot towards greater attention to national security issues and human rights concerns, this pattern seems likely to continue.

In addition, there was recently another indicator of the likelihood of increased enforcement of Canadian sanctions, the violation of which is a criminal offence. Press reports on November 21, 2022 stated that the U.S. government is quietly pressing its allies to tighten up sanctions enforcement in regard to sanctions on Russia.

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