The Office of the Superintendent of Financial Institutions (OSFI) recently announced the easing of certain economic sanctions against Iran. According to the Government of Canada, these actions have been taken in concert with international efforts to recognize the progress that Iran has made to scale down its nuclear program and to subject it to international monitoring under the Joint Comprehensive Plan of Action.
Effective February 5, 2016, amendments were made to the Special Economic Measures (Iran) Regulations(SEMA Iran Regulations), enacted pursuant to the Special Economic Measures Act, to remove broad prohibitions on providing or acquiring financial or other services to or from Iran. The amendments also remove the prohibition on investing in Iranian entities. Finally, the amendments modify the list of individuals and entities listed in Schedule 1 to the SEMA Iran Regulations that are subject to various sanctions, including an asset freeze and a prohibition on certain dealings.
The remaining prohibitions under the SEMA Iran Regulations, however, are not insignificant. The duty to determine whether prescribed financial institutions and registrants are in control or possession of property of listed individuals and entities persists, though that list of individuals and entities is significantly truncated under the amended SEMA Iran Regulations. In addition, any person in Canada or any Canadian outside of Canada is prohibited from exporting, selling, supplying or shipping any of the goods listed in Schedule 2 to the SEMA Iran Regulations to Iran or to a person for the purpose of a business carried on in or operated from Iran. Those listed goods are also subject to a prohibition on the transfer, provision or disclosure of technical data related thereto.
In addition to the SEMA Iran Regulations, OSFI announced on the same day that the Regulations Implementing United Nations Resolutions on Iran, enacted pursuant to the United Nations Act, were amended effective January 16, 2016 to remove twenty individuals and seventeen entities from its Consolidated List of Individuals and Entities.