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In this post we describe the sanctions recently imposed by Canada on Iranian individuals and entities following the detention and, according to the Canadian government, apparent killing of Mahsa Amini, an Iranian woman, in Iranian morality police custody.

On October 3, 2022, Canada amended the Special Economic Measures (Iran) Regulations to list an additional 25 individuals and nine entities in relation to Irans gross and systematic violations of human rights and/or Irans ongoing grave breach of international peace and security. These new sanctions follow over nine years of the Canadian government not imposing further sanctions on Iran (the 2016 amendments to Canadas sanctions on Iran were largely a loosening of restrictions following the P5+1 agreement in relation to Irans nuclear program). The impetus for the new sanctions appears to have been the death in Iranian police custody of Ms. Amini. For those who follow the Canadian governments policy objectives it is not surprising that this event was the catalyst for revisiting and tightening Canadas sanctions program on Iran.

Ten Iranian individuals were designated on the basis of the Canadian governments opinion that gross and systematic human rights violations have been committed in the Islamic Republic of Iran and that these individuals had sufficient involvement in such violations to merit being designated by Canada. Nine entities were designated on this basis including the Islamic Revolutionary Guard Corps Cyber Defense Command, Evin Prison, the Office of the Enjoining Right and Forbidding Evil, the Ministry of Intelligence and Security (MOIS) and the Morality Police. Many of the designated individuals lead designated entities.

In addition, 15 Iranian individuals were designated on the basis of the Canadian governments opinion that the actions of the Islamic Republic of Iran constitute a grave breach of international peace and security that has resulted or is likely to result in a serious international crisis and that these individuals had sufficient involvement in such actions to merit being designated by Canada. These amendments signal concern about Irans activities in the weapons of mass destruction and/or terrorism areas. In that regard it is worth noting that the news release issued by Canada in connection with the new designations specifically referenced the Canadian governments 2012 designation of Iran as a state sponsor of terrorism under the State Immunity Act.

Given the long-established (but possibly now somewhat diminished) business relationships between Iranian and Canadian persons it is important that Canadian businesses assess whether these new sanctions have any implications for their compliance activities.

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Canada Imposes New Sanctions on Iran in Relation to Human Rights Violations and Irans Actions That Have Resulted or Are Likely to Result in a Serious...

I have too much respect for our friends and our allies to tell them what they should do, Rama said. We are always very careful to be very humble in our assessments.

The discussion inside the Albanian government over triggering Article Five underscores the ongoing debate as to whether a cyberattack will ever be serious enough to truly trigger a full-blown NATO collective defense response which could involve cyber retaliation against the attacking country by all NATO members or crippling sanctions. The provision has only been triggered once, just days after the Sept. 11 attacks on the United States, and the consequences have not been fully spelled out for a cyberattack. NATO member countries must come to the aid of the nation that invokes Article Five, but each member country can determine the extent of their response.

For Rama, the July attack which forced the country to shut down websites across government used for everything from paying utilities to obtaining drivers licenses walked right up to the line.

Its like bombing a country, Rama said of the cyber strike, which was widely attributed to Iranian hackers. Ninety-five percent of Albanias government services are provided online, meaning daily operations halted at government offices across the country, he said. The hackers also attempted to wipe sensitive government data, he said, but were not successful.

Albania severed diplomatic relations with Iran in response believed to be the first time a nation has taken this step due to a cyberattack. But Rama decided against taking the incident to NATO.

It was too much for us to think about and to get to the decision that we should ask NATO to trigger Article Five, Rama said.

In likely retaliation for the severing of relations, Iranian hackers again attacked Albania in early September, disabling certain systems used in border and customs processing. Rama warned that his nation expects more attacks from Iran, and is working to strengthen cyber defenses.

The line around when a cyberattack could trigger Article Five is unclear. The NATO Cooperative Cyber Defence Centre of Excellence described the application of it to a cyberattack as a blurry but consistent position of NATO, while NATO Secretary General Jens Stoltenberg said in 2018 that the level of cyberattack to trigger collective defense must remain purposefully vague.

I am often asked, under what circumstances would NATO trigger Article Five in the case of a cyberattack? My answer is: we will see, Stoltenberg said at the time.

Jim Lewis, director of the Strategic Technologies Program at the Center for Strategic and International Studies, said NATO is likely still working through the menu of options it would use to respond to a cyberattack. Its going to be messy for a while until we sort out what you can do short of violence that can have [an] effect.

The Iranian cyberattacks may have caused widespread disruption, but did not lead to any deaths or permanent destruction of systems. These facts, paired with the smaller size of Albania in terms of geography and population, made triggering Article Five even more remote.

If the attack had been more damaging, they might have gotten some support, Lewis said. No one was hurt, so its hard to make the case that its Article Five.

The Russian invasion of Ukraine has intensified these discussions, given recent warnings that Russia is preparing to intensify cyberattacks against Ukraine as the winter months approach, and that a cyberattack against Ukraine could spill over into neighboring countries that belong to NATO.

Many NATO members, including Albania, have provided cybersecurity support to Ukraine.

We have done our part, Rama said of Albanias assistance, but whats happened with Iran imposes a different speed.

NATO and its member states did take actions to support Albania after the July strike. NATO released a statement condemning the attack and pledging to provide support to strengthen Albanias cyber defense. The U.S. Treasury Department sanctioned Irans intelligence agency and its leader, and the Justice Department indicted alleged Iranian hackers for widespread attacks against global critical infrastructure.

The FBI and the Cybersecurity and Infrastructure Security Agency released a joint advisory in September detailing how the Iranian hackers gained access to the victimized Albanian networks 14 months prior to the attack being carried out, periodically stealing emails associated with the government of Albania. The British government noted in a separate alert that Ramas emails were among those accessed.

Rama pointed to U.S. assistance following the attack, which included providing in-person expertise to investigate the incident, as a big support, and noted that Albania is currently awaiting U.S. financial aid for cyber defense efforts.

Every dollar that will come will be very much appreciated, Rama said. I think they should and they will show that they support us in this situation.

See the article here:
Albania weighed invoking NATO's Article 5 over Iranian cyberattack - POLITICO

OTTAWAThe Canadian government has not yet designated Irans revolutionary guard corps as a terrorist entity over concerns the action would be overbroad, difficult to enforce and unfairly target potentially thousands of Iranians in Canada who may have been conscripted by Irans military, sources tell the Star.

Prime Minister Justin Trudeau said Wednesday his government will hold the bloodthirsty regime to account, and that Canada will continue to sanction the leadership of the Islamic Revolutionary Guard Corps, but he stopped short of answering yes or no to Conservative Leader Pierre Poilievres demand he recognize the IRGC as a terrorist group.

Faced with growing calls for action by the Conservatives, families of Canadian victims killed when Iran shot down flight PS752 and now in the face of a global uproar over the death of a young Iranian woman who wasnt wearing a hijab, the federal Liberal government says it intends to do more to sanction human rights abuses by the Iranian regime.

Everything is absolutely on the table, Deputy Prime Minister Chrystia Freeland said Wednesday.

Some of this is very complicated, getting the details right is complicated, avoiding collateral damage is important, Freeland said, the day after meeting with families of the 2020 plane crash victims.

Freeland added, But from my perspective, theres actually something very simple at the heart of this, which is Canada and Canadians need to be on the side of women women and students who are brave enough to protest, and not on the side of misogynist repressive theocrats.

Canadian government officials have for years looked at the question of putting the IRGC, a branch of Irans armed forces, on the terrorist list under the Criminal Code, three sources said.

But ministers this week have repeatedly declined to state why Canada has not done so already.

Canada listed Iran as a state supporter of terrorism under the State Immunity Act in 2012.

A formal designation of a terrorist group makes it possible to freeze or seize an entitys property and requires banks and financial institutions to block and report any transactions.

Yet multiple sources said a terrorist listing of the IRGC would have an impact potentially on Iranian-Canadian citizens and permanent residents drafted into military service in Iran who would no longer be able to travel or send money to support family still living there.

The IRGC is a branch of the Iranian armed forces, and therefore a state actor, and there is no precedent for listing a state as a terrorist organization.

A senior government source acknowledged there would be challenges to monitoring and enforcing such a terrorist listing, but declined to elaborate.

Government officials declined to disclose numbers or estimates of how many Iranians in Canada could be affected by such a designation.

One official said it would also mean any person who ever served in the IRGC would be deemed inadmissible to Canada.

In 2012, the previous Conservative government expelled Iranian diplomats, closed Canadas embassy in Tehran, and listed the IRGCs Quds Force as a terrorist entity. The Quds Force is the clandestine branch of the IRGC responsible for funding, arming and training extremist operations of external groups like the Taliban, Hezbollah, or Hamas.

Since cutting diplomatic ties, Canada has had to rely on proxies like Italy and Switzerland to aid in consular emergencies, such as when Concordia University professor Homa Hoodfar was imprisoned.

The U.S. under former president Donald Trump listed the IRGC as a terrorist entity in 2019 after accusing Iran of continuing nuclear weapons development. President Joe Biden has retained that designation.

In 2018, MPs unanimously supported a motion urging Canada to do just that.

Conservative foreign affairs critic Michael Chong this week accused the government of doing nothing once the headlines faded.

Freeland and other ministers were heckled at a rally on Parliament Hill in Ottawa on Tuesday. She said Wednesday, their fight for justice is Canadas fight, and its very important for them to know that.

Thomas Juneau, a former policy analyst at the federal defence department now with the University of Ottawas Graduate School of Public and International Affairs, said in an interview there may be rhetorical symbolic value for Canada to take the step of putting the terrorist label on the IRGC, but if it cannot enforce it, there is also a cost to government credibility.

He said even if Ottawa wanted to carve out an exemption for low-level conscripts, some conscripts have blood on their hands while others dont, and how do you know that?

The Iranian government is not going to open their databases for us to verify if this individual actually was a conscript, was really a cook, and what kind of combat training did he have, and what mission was he deployed on, and so on, he said.

Liberal MP Rob Oliphant, parliamentary secretary for foreign affairs, said in an interview, if it were simple to do, it would have been done already.

Oliphant said the government needs to make sure that we dont cause more pain and suffering to Canadians who are here, who are contributing or engaged. He said Ottawa also doesnt want to limit opportunities for people to get out of Iran in the future who may be trying to escape that tyrannical regime or limit its already diminished ability to help Canadians in consular emergencies in that country.

We hear the call from Iranian Canadians its a strong call to list, so were obviously trying to find a way to do it that causes the least amount of damage possible, Oliphant said. How do we do that and carve out something legislatively that has more subtlety and more finesse than a simple listing?

He pointed to an exchange he had last week, when an Iranian-Canadian sought his help, asking: Cant Canada negotiate something with the United States so I can travel to the United States for work; I cannot go because I was conscripted into the IRGC as a young Iranian. I did my military service there, I cannot go to the United States. I am allowed to come to Canada. I became a PR (permanent resident), I became a citizen. Im engaged in society here. I passed every security clearance for Canada. United States has said Im not allowed to go there because Im a terrorist.

This week, the Liberal government levied new sanctions against 25 individuals and nine entities in response to the death of Mahsa Amini at the hands of Irans so-called morality police over the alleged crime of not wearing a hijab. To date, Canada has levied sanctions on a total of 66 individuals and 170 entities.

Jessica Davis, a former analyst with CSIS and an expert in counterterrorism money-laundering, said there is very little public transparency on just how effective previous Iran sanctions have been, or to what extent they have been violated.

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Pierre Poilievre is demanding it but insiders reveal why Canada wont brand this Iran military group as terrorists - Toronto Star

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DUBAI, Sept 16 (Reuters) - A young Iranian woman has died after falling into a coma following her detention by morality police enforcing Iran's strict hijab rules, sparking protests by Iranians on social media and on the streets on Friday.

In the past few months, Iranian rights activists have urged women to publicly remove their veils, a gesture that would risk their arrest for defying the Islamic dress code as the country's hardline rulers crack down harder on "immoral behaviour". read more

Videos posted on social media have shown cases of what appeared to be heavy-handed action by morality police units against women who had removed their hijab.

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Authorities launched probes into the death of Mahsa Amini following a demand by President Ebrahim Raisi, state media reported. Police said the 22-year-old was taken ill as she waited together with other detained women at a morality police station.

"Since her transfer to the vehicle and also at the location (station), there was no physical encounter with her," a police statement said, rejecting allegations on social media that Amini was likely beaten.

Closed-circuit television footage carried by state TV appeared to show a woman identified as Amini falling over after getting up from her seat to speak to an official at a police station. Reuters could not authenticate the video.

Police earlier said Amini had suffered a heart attack after being taken to the station to be "educated". Her relatives have denied she suffered any heart condition.

Several prominent sports and arts figures posted critical social media comments about Amini's death, and outspoken reformist politician Mahmoud Sadeghi called on Supreme leader Ayatollah Ali Khamenei on Twitter to speak out as he had denounced the killing of George Floyd by U.S. police in 2020.

Postings on social media included videos showing protesters chanting "Death to the dictator (Khamenei)" as drivers sounded their car horns to back protests in a Tehran square near Amini's hospital amid a heavy police presence.

As during past protests, authorities appeared to have restricted internet access in the capital Tehran to make it difficult for protesters to post videos on social media.

Internet blockage observatory NetBlocks reported on Twitter that there was "a significant internet outage" in Tehran, linking the incident to the protests.

U.S. special envoy for Iran, Robert Malley, said on Twitter: "Mahsa Aminis death after injuries sustained in custody for an 'improper' hijab is appalling ... Those responsible for her death should be held accountable."

Rights group Amnesty International said on Twitter: "... allegations of torture and other ill-treatment in custody, must be criminally investigated ... All agents and officials responsible must face justice."

Under Iran's sharia (Islamic) law, imposed after the 1979 revolution, women are obliged to cover their hair and wear long, loose-fitting clothes to disguise their figures. Violators face public rebuke, fines or arrest.

Decades after the revolution, clerical rulers still struggle to enforce the law, with many women of all ages and backgrounds wearing tight-fitting, thigh-length coats and brightly coloured scarves pushed back to expose plenty of hair.

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Reporting by Dubai newsroom, additional reporting by Arshad Mohammed in Saint Paul, Minn.; Editing by William Maclean, Jonathan Oatis and Grant McCool

Our Standards: The Thomson Reuters Trust Principles.

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Iran woman's death after morals police arrest sparks protests - Reuters

National Security

Roxane Farmanfarmaian claims Tehran would not use a nuclear weapon against Israel

Iran should be allowed to build a nuclear weapon, according to the Quincy Institute for Responsible Statecraft's newest hire, Roxane Farmanfarmaian.

Farmanfarmaian, a policy analyst who focuses on Iran, earlier this month became a nonresident fellow at the isolationist think tank bankrolled by billionaires George Soros and Charles Koch. In a 2013 policy debate, Farmanfarmaian argued in favor of Iran building a nuclear bomb, saying the country would never use it to destroy Israel, even though the hardline regime has been threatening to do so for years and sponsors the top jihadist terrorists waging war on the Jewish state.

Farmanfarmaian joins a growing roster of Quincy Institute scholars who have pushed for increased engagement with Iran and promoted anti-Israel conspiracy theories from their perch at the think tank. This includes Trita Parsi, who formerly helmed the National Iranian American Council, a groupaccusedof secretly lobbying on Iran's behalf, andStephen Walt,a longtime Israel critic who has pushedconspiracy theories about the Jewish state. Like many of her Quincy Institute colleagues, Farmanfarmaian has downplayed the threat posed by a nuclear-armed Iran and argued that Israel should learn to live with the threat of an Iranian bomb.

"If Iran was to bomb Israel, it would destroy Jerusalem, the third-holiest site in Islam," Farmanfarmaian was quoted as saying during the debate, according to a press report published at the time. "It's inconceivable that Iran would bomb Israel because it would isolate it."

Israeli leaders and a wide array of regional experts disagree with this assertion.

Farmanfarmaian also argued in a 2020 op-ed published in the Nation that then-president Donald Trump's assassination of Iranian general Qassem Soleimani was "a colossal strategic blunder." Like other Quincy scholars and pro-Iran analysts, Farmanfarmaian argued the assassination would spark a global terror spree by Iran, a fear that never came to fruition.

She also described the general, who helmed Iran's regional terror operations, as "charismatic and highly effective."

Soleimani, "largely immune from the ambivalence with which many Iranians view the ruthless Islamic Revolutionary Guard Corps, operated for the most part outside the country as the respected head of the IRGC's foreign arm, the elite Quds Force," she wrote at the time. "Charismatic and highly effective, he gained admiration even among reformists for expanding Iran's reach across the Shia Crescent, the land bridge connecting Iran to Iraq, Syria, and Lebanon."

Farmanfarmaian went on to claim that the Soleimani assassination genuinely upset ordinary Iranians, even though the general was widely seen as the face of Tehran's massive spending on foreign wars.

"The expressions of grief on the streets of Iran are genuine," she wrote. "His assassination has brought the population closer to the leadership, despite recent protests, in shared outrage not only at Trump's actions but also at the administration's apparent disdain for Iran's sovereign rights and its insulting rhetoric demanding that Iran change its behavior.'"

See more here:
Give Iran Nukes, Says Quincy Institutes New Iran Expert - Washington Free Beacon