Introduction

On October 3, 2022, the Honourable Melanie Joly, Canada’s Minister of Foreign Affairs, announced that Canada was imposing sanctions on 25 Iranian officials and 9 Iranian entities/organizations that are directly involved with implementing “repressive measures [to] violate human rights and spread the Iranian regime’s propaganda and misinformation.”[1] This announcement comes just one week after Prime Minister Justin Trudeau announced Canada’s intention to impose sanctions on Iranian individuals and its leadership.

Canada’s sanctions are in response to alleged human rights violations, including Mahsa Amini’s death. Amini died while in the custody of Iran’s Morality Police. Amini was arrested on September 13, 2022, in Tehran for “unsuitable attire” by the Morality Police. Amini’s family allege that she was beaten to death while in police custody, while Iran’s police authorities have denied those allegations and responded that Amini died of a heart attack. Amini was 22 years old when she died.

The Sanctions

The sanctions are being imposed under the Special Economic Measures (Iran) Regulations. They include:

  • A freeze on the targeted individuals’ and entities’ assets in Canada; and
  • A Canadian entry ban on senior officials playing a leading role in implementing repressive measures and human rights violations in Iran.

The newly sanctioned individuals are:

  1. Major General Mohammed Hussein Bagheri, Chief of Staff of Iran’s Armed Forces
  2. Hossein Salami, Commander-in-Chief of the Islamic Revolutionary Guard Corps (“IRGC”)
  3. Esmail Qaani, Commander of the Quds Force of the IRGC
  4. Esmail Khatib, Minister of Intelligence and Security
  5. Mohammad Rostami Cheshmeh, Head of the Morality Police
  6. Sayyed Mohammed Saleh Hashemi Golpayegani, Secretary of Iran’s Headquarters of the Office of Enjoining Right and Forbidding Evil
  7. Ali Shamkhani, Secretary of the Supreme National Security Council
  8. Mohammad Bagher Ghalibaf, Speaker of Parliament
  9. Ahmad Vahidi, Minister of the Interior
  10. Alireza Tangsiri, Commander of the Navy of the IRGC
  11. Gholamreza Soleimani, Senior Officer in the IRGC Corps
  12. Mohsen Razaei, Vice-President of Iran for Economic Affairs
  13. Safer Ali Mousavi, Chief Commander of the IRGC’s Intelligence Unit in the province of Sistan-Baluchestan
  14. Zeinab Soleimani, Head of Qassem Soleimani Foundation
  15. Ahmad Jannati, Chairman of Iran’s Assembly of Experts
  16. Saeed Jalili, Member of the Expediency Discernment Council
  17. Sayyed Abdolrahim Mousavi, Commander-in-Chief of Iran’s Army
  18. Ali Akbar Velayati, Member of the Expediency Discernment Council
  19. Gholam-Hossein Mohsei-Eje’I, Chief Justice of Iran
  20. Hassan Rouhani, Former President of Iran
  21. Mahmoud Alavi, Former Minister of Intelligence
  22. Hossein Ashtari, Commander-in-Chief of Law Enforcement of Iran
  23. Issa Zarepour, Minister of Information and Communications Technology of Iran
  24. Sadeq Ardeshir Larijani, Chairman of the Expediency Discernment Council
  25. Mohammad Rostami Cheshmeh Gachi, Head of Iran’s Morality Police

The newly sanctioned entities are:

  1. IRGC’s Cyber Defense Command
  2. The Basij Cooperative Foundation
  3. Basij Resistance Force
  4. Iran’s Morality Police
  5. Evin Prison, which houses political prisoners
  6. Ministry of Intelligence and Security (MOIS)
  7. Office of the Enjoining Right and Forbidding Evil
  8. Qassem Soleimani Foundation
  9. Press TV

Next Steps

In addition to these new sanctions, Canada continues to impose sanctions on a total of 41 Iranian individuals and 161 Iranian entities, including the IRGC and the Iranian state’s security, intelligence, and economic apparatus.

Canada is among several countries who have responded to recent unrest in Iran by proposing sanctions against state-affiliated individuals and state or commercial entities. For example, on October 3, 2022, Germany, France, Denmark, Spain, Italy, and the Czech Republic submitted 16 proposals for new European Union sanctions against Iran. The US imposed sanctions on Iran’s Morality Police, among other Iranian officials, on September 22, 2022.

Foreign policymakers and geo-political analysts remain uncertain whether Canada and its allies will impose further sanctions on Iran. However, given that clashes between protestors and Iranian security forces continue and unrest remains ongoing, there is an expectation that these new sanctions will be maintained and may be escalated for at least the foreseeable future.

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About the Authors:

Jemark Earle is an Articling Student in the firm’s Toronto office. He can be reached at 416-777-4024 or learle@dickinsonwright.com. To read his full bio, please click here.

 

 

 

Dan Poliwoda is an Associate in Dickinson Wright’s Toronto office. Dan can be reached at 416-646-6870 or dpoliwoda@dickinsonwright.com , and his bio can be accessed here.

 

 

 

Wendy Hulton is a Partner in Dickinson Wright’s Toronto office. Wendy can be reached at 416-777-4035 or whulton@dickinsonwright.com , and her bio can be accessed here.

 

 

 

[1] Under the Special Economic Measures Act, the Government of Canada is authorized to impose sanctions on foreign jurisdictions and persons where it believes that a grave breach of international peace and security has occurred that has resulted or is likely to result in a serious international crisis.

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