Canada’s Sanctions Regime Regarding Iran: How Much has Changed in a Post-Joint Comprehensive Plan of Action Regulated Market?

Abstract

The negotiation of the Joint Comprehensive Plan of Action (‘JCPOA’) further to the United Nations Security Council (‘UNSC’) Resolution of 20 July 20151 (‘July 2015 UNSC resolution endorsing the JCPOA’) portends, on full implementation, several significant changes affecting commercial and financial transactions in and with Iran.2 However, for anyone in Canada and Canadians abroad, the question is whether the JCPOA will result in a repositioning of Canadian sanctions compliance regarding Iran to respond to this evolving Iran sanctions regime. This article will explain that although there will be changes to Canada’s sanctions regime for Iran, most of the current sanctions regime will remain in place now and that for most business in Canada the status quo will prevail for the foreseeable future. This article discusses why. But before doing so, it is important to note that Canadian regulators can seek and in fact have sought criminal sanctions including incarceration for violations of Canada’s sanctions laws on Iran.