Key Takeaways
- Canada sanctioned 73 names in two days — 11 Iranian entities brought back, plus 38 Russian entities and 24 individuals.
- A listing is a total dealings ban that binds everyone in Canada and Canadians abroad.
- Breaking Canadian sanctions is a criminal offence, with prison time on indictment.
Canada added 73 names to its sanctions lists. Here's what that means for your bank account.
Imagine trying to pay someone, transfer money or complete a business deal — only to discover that the law now prohibits the transaction.
That's the power behind Canada's latest sanctions.
On November 9, Ottawa sanctioned 38 Russian entities and 24 individuals, including missile-technology developers, cyber actors and crypto exchanges helping fund Russia's war economy.
A day later, at the G7 foreign ministers' meeting in Paris, Foreign Minister Anita Anand announced sanctions against 11 Iranian entities — including the National Iranian Oil Company, National Iranian Tanker Company, Bank Mellat and Bank Melli Iran.
There is a twist: Canada had removed these Iranian names from its sanctions list in 2016, when the Iran nuclear deal took effect.
"Iran must never be allowed to obtain a nuclear weapon," Anand said.
But a sanctions announcement is only the beginning. The real question is what happens after someone's name lands on the list.
Three laws, but one tool used twice this week
Canada has three main legal routes for imposing sanctions.
The United Nations Act implements sanctions decided by the UN Security Council. Ottawa has no choice when implementing those decisions.
The Justice for Victims of Corrupt Foreign Officials Act, Canada's Magnitsky law, targets individual human-rights abusers and corrupt foreign officials.
But both rounds this week used the third law: the Special Economic Measures Act (SEMA).
SEMA allows Canada to impose its own sanctions in situations involving a grave breach of international peace and security or gross, systematic human-rights violations.
The government creates regulations naming specific individuals and entities.
And once those names appear in the applicable regulations, the legal consequences begin.
What happens when your name is on the list?
A SEMA listing effectively freezes assets through what is called a dealings ban.
Everyone in Canada — and every Canadian outside the country — is prohibited from dealing in a listed person's property, facilitating transactions involving that property or providing financial and related services to them or for their benefit.
And property doesn't just mean cash.
It can include real estate, vehicles, equipment, artwork, financial instruments and intellectual property.
There is another important catch: using someone else to get around the restrictions doesn't necessarily work.
Property belonging to an entity owned or controlled by a listed person can also be caught by the restrictions. The deemed-ownership threshold is 50% or more, although actual control can matter even without that ownership percentage.
A listed individual also becomes inadmissible to Canada under immigration law.
In other words, the consequences can extend well beyond the person or company whose name appears in the announcement.
Why Iranian names are appearing again
The Iran sanctions story has a longer history.
Canada first imposed sanctions on Iran under SEMA in July 2010.
After the 2015 nuclear deal, Ottawa eased its measures in February 2016, removing the 11 entities now back on the list.
Then came another turning point.
The International Atomic Energy Agency found Iran non-compliant in June 2025. European powers subsequently triggered snapback, and UN sanctions returned in September 2025.
Now Canada has restored its own autonomous sanctions against those 11 entities.
The same names. A different political and legal moment.
The rules apply to Canadian businesses too
Sanctions aren't just a government-to-government issue.
Canadian companies, banks and individuals must comply. And following American sanctions does not automatically mean complying with Canadian ones. The lists can differ.
There are also positive reporting obligations: certain holdings connected to frozen assets must be disclosed. Suspected violations can be reported to the RCMP's Federal Policing Operations Intake Unit.
Enforcement involves the RCMP and the Canada Border Services Agency.
Breaking SEMA sanctions is a criminal offence.
The maximum penalties are:
- Summary conviction: a fine of up to $25,000 and up to one year in jail.
- Indictment: up to five years in prison.
There are two important qualifications. Sanctions aren't retroactive: restrictions take effect from the date a listing comes into force, sometimes with a wind-down period. The foreign minister can also issue permits allowing otherwise prohibited transactions in exceptional circumstances.
One final detail matters: the government's Consolidated Canadian Autonomous Sanctions List is a searchable reference, not the law itself. The legally authoritative lists are the schedules attached to the relevant regulations.
The Twikup Take
Canada didn't just announce 73 new names this week. It changed what Canadians are legally allowed to do with certain people, companies and their assets.
A bank transfer, business transaction or financial service that looks perfectly ordinary can become a criminal offence when sanctions apply.
The announcement makes the headlines. The regulations determine what Canadians can legally touch.
Image: Illustrative image.
