Sanctions and Export Control Alerts: Stay Informed. Stay Compliant.

Canada announced the listing of four additional Iranian individuals today under the Special Economic Measures (Iran) Regulations. According to the announcement, these individuals, all Iranian senior officials, have been involved in gross and systematic human rights violations Iran, and have had a significant role in facilitating and directing repressive policies.

The four individuals are:

• Mohsen Karimi
• Ahmad Kadem Seyedoshohada
• Mustafa Mohebbi
• Hassan Akharian

Though announced today, these amendments came into effect on December 12, 2025.

More details are available here: https://www.canada.ca/en/global-affairs/news/2025/12/backgrounder---canada-imposes-further-sanctions-against-iran.html.

On December 10, 2025, Canada announced the addition of four new entities to its terrorist list under the Criminal Code: Maniac Murder Cult (MMC),  Terrorgram Collective, Islamic State-Mozambique (IS-M), and 764. These are now considered "terrorist groups" under the Criminal Code such that the following is prohibited: engaging in direct or indirect dealings in, or facilitation of transactions in respect of, property owned or controlled by these groups;  providing financial or related services in respect of their property or to or for their benefit; and collecting, providing or making available property or financial or other related services that will in whole or in part be used by or benefit these groups. Property owned or controlled by these groups must be frozen and reported to either the RCMP or CSIS. More details here: https://www.canada.ca/en/public-safety-canada/news/2025/12/government-of-canada-lists-four-new-terrorist-entities0.html.

On December 5, 2025, following similar steps taken by the United States and the United Kingdom earlier this year, Canada removed Hay’at Tahrir al-Sham (HTS) from its terrorist entity list under the Criminal Code. Syria has also been removed from the List of Foreign State Supporters of Terrorism under the State Immunity Act. More details can be found here https://www.canada.ca/en/global-affairs/news/2025/12/canada-announces-measures-related-to-syria.html. HTS remains on the United Nations sanctions list and is therefore subject to prohibitions under Canada’s Regulations Implementing the United Nations Resolutions on Taliban, ISIL (Da’esh) and Al-Qaida.  Further, economic sanctions measures against Syria remain in place under the Special Economic Measures (Syris) Regulations, including a broad prohibition on providing or acquiring financial or related services to, from or for the benefit of any persons in Syria, subject to the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations which allows for certain activities and transactions “aimed at the democratization and stabilization of Syria or the delivery of humanitarian assistance to or within Syria”.

Canada’s recently announced 2025 Budget contains a number of important international trade and investment measures and key among them relate to the growing role of the Minister of Finance in economic sanctions, including: a requirement that the Minister of Finance be consulted before foreign financial institutions, central banks, payment service providers, stock exchanges or clearing and settlement systems are added to Canada’s sanctions lists;  new powers for the Finance Minister to direct that any profits generated from sanctioned property held by federal financial institutions be remitted to the government as a so-called “Targeted Windfall Profit Charge” is intended “to serve public policy objectives”; and laying the groundwork for establishing a Financial Crimes Agency which would become Canada’s lead enforcement agency for financial crimes – including sanctions enforcement. The 2025 Budget also proposes to amend Canada’s Export and Import Permits Act to allow the government to restrict the importation or exportation of items in response to actions of another country that harm Canada or to create more secure and reliable supply chains. More details here: Budget 2025: Key International Trade and Investment Highlights.

Canada has issued long-awaited guidance on application of export and technology transfer controls to cloud computing. In the November 10, 2025 Notice to exporters no 1159 – Guidance on the movement to and storage of controlled technology in the Cloud, Global Affairs Canada’s Strategic Export Controls Bureau clarifies how cloud computing intersects with Canada’s Export and Import Permits Act (EIPA). According to the Bureau, in the cloud context controlled technology is considered to be exported or transferred under the EIPA “if it is sent from Canada and stored in a foreign location in a way that creates a reasonable possibility that a person located outside of Canada would be in a position to examine that technology.” It also notes that “reasonable possibility means more than a mere possibility, but less than the standard of more likely than not. In other words, if there is more than a remote possibility that the controlled technology may be examined by a person outside of Canada in a usable form – either directly or because they hold decryption keys or access rights in a way that creates more than a remote possibility of access – the movement and storage of technology outside of Canada may be considered a “transfer” and require an exporter to apply for a permit.” The notice also addresses topics such as encryption standards, key management practices, shared responsibility between cloud providers and users, and risk mitigation strategies for emerging technologies like AI and machine learning—particularly when these involve controlled technical data or automated processing that could expose sensitive information abroad. It emphasizes that AI-driven systems must be configured to prevent unauthorized foreign access to controlled technology.

On November 5, 2025, Global Affairs Canada (“GAC”) published new interpretive guidance for compliance with Canada’s sanctions regimes (the “Updated Guidance”), followed by expanded Frequently Asked Questions (the “FAQs”), last updated November 27, 2025. The Updated Guidance focusses on practical sanctions-compliance scenarios and reiterates GAC’s broad interpretation of the 2023 Deemed Ownership Rule under SEMA and the JVCFOA — including the view that “considerable influence over strategic decision-making” may suffice to establish control, despite this language not appearing in the statutes. GAC has additionally released sector-specific modules for the academic, financial, real estate, and humanitarian sectors, emphasizing enhanced due diligence, indirect-ownership risks, and rising enforcement expectations (including FINTRAC reporting and new requirements effective in 2025). The updated FAQs include new answers addressing how the sanctions regime is being enforced, the application of the Special Economic Measures Act (SEMA) – Russia Regulations and the application of sanctions to academic institutions.