Canadian regulators have taken 2 recent steps in enhancing their sanctions enacted against Syria & Iran under the Special Economic Measures Act (SEMA):
On November 28th, the Governor in Council added 10 individuals and 3 entities, and removed 2 individuals and 1 entity from the SEMA Syria Regulations.
On December 11th, the Governor in Council made three functional changes to the SEMA Iran Regulations:
- Provision of insurance and reinsurance to Iran is now prohibited
- Provision of any hard currency in excess of 40,000 CAD is now prohibited
- Legal fees to dispute designation under the SEMA Iran Regulations are now permitted
In addition, a number of changes were made to the list of Designated Persons and Entities under the SEMA Iran Regulations.
While OSFI announces these changes, as they are the Canadian financial system regulator, DFAIT, which is the foreign policy arm of the Canadian government, is the department where the regulations are maintained. The December 11th release is very clear on this matter, in particular how the SEMA regulations are separate from, and in addition to, the regulations that implement the UN’s Syrian sanctions program (which appears to be maintained by OSFI, although I have not investigated this in detail) – and that OSFI would not be maintaining a list of Designated Individuals who are sanctioned under SEMA alone.
Categories: OSFI Updates