November 22, 2022 | Flash Brief

Canada Intensifies Sanctions on Iran, But Further Action Needed

November 22, 2022 | Flash Brief

Canada Intensifies Sanctions on Iran, But Further Action Needed

Latest Developments

The Canadian Security Intelligence Service is investigating Iranian death threats against Canadians who have publicly criticized Tehran, the spy agency said last week. The announcement appears to reflect Ottawa’s increasing efforts to hold Iran accountable for its bloody suppression of anti-regime protests. Last Wednesday, Canada imposed its fifth round of sanctions this year against regime targets pursuant to the Special Economic Measures Act, bringing Ottawa’s total number of designations to 280. However, Ottawa has stopped short of perhaps the most impactful step it could take: designating Iran’s Islamic Revolutionary Guard Corps (IRGC) as a terrorist organization pursuant to Canada’s Criminal Code.

Expert Analysis

“If Canada’s goal is to have a real impact, to thwart the rampant human rights abuses of the Iranian people, to meaningfully deter threats from Iran’s Revolutionary Guards abroad, to stem the use of Canada for laundering money by regime cronies, and to begin to see cracks in the regime itself, sanctions need to have more teeth and be fully enforced.” Toby Dershowitz, FDD Senior Vice President for Government Relations and Strategy

Iran’s Violent Repression of Protests Continues

Iranian security forces have killed at least 434 protesters, including 60 children, and arrested 17,473 people over the past two months, the Human Rights Activists News Agency reported on Monday. Over the weekend, in a massive show of force, Iranian military forces penetrated Iran’s Kurdish regions with helicopters and armored vehicles, killing an unknown number of people. “I have witnessed hundreds of people being shot at [by the regime forces] and they have been severely injured,” said one Iranian. On Monday, the IRGC reportedly opened fire on protesters using machine guns.

Canadian Sanctions on Iran Pursuant to the Immigration and Refugee Protection Act

On November 14, Canada designated Iran under the Immigration and Refugee Protection Act as a regime that has engaged in terrorism and systematic and gross human rights violations. Complementing Iran’s 280 other sanctions designations, this step renders tens of thousands of senior regime members, including many IRGC members, inadmissible to Canada. It also makes current and former senior Iranian officials residing in Canada eligible for investigation and removal from the country.

Canada Needs Stronger Measures against Iran

Canada has yet to designate the IRGC as a terrorist group pursuant to the Criminal Code — the toughest measure in Ottawa’s sanctions toolkit. Canada has also refrained from sanctioning Iran’s oil industry as well as financial institutions such as the Central Bank of Iran that hold accounts for the IRGC. In 2012, Canada did designate the IRGC Quds Force — but not the IRGC in its entirety — as a terrorist organization under the Criminal Code. In 2018, the House of Commons overwhelmingly passed a resolution urging the government to sanction the entire IRGC pursuant to the Criminal Code.

Related Analysis

Maximum Support for the Iranian People: A New Strategy,” by Saeed Ghasseminejad, Richard Goldberg, Tzvi Kahn, and Behnam Ben Taleblu

Canada must designate Iran’s revolutionary guard as a terrorist group,” by Tzvi Kahn


Iran Iran Global Threat Network Iran Sanctions Iran-backed Terrorism Sanctions and Illicit Finance