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| Sergio R. Karas |
The Canada Border Services Agency (CBSA) is currently investigating and taking enforcement action in 66 cases involving individuals suspected of being senior Iranian officials who may have entered or remained in Canada despite sanctions prohibiting their entry or presence in the country. According to data obtained by the Globe and Mail, 20 of these individuals have already been found inadmissible on the grounds that they are believed to be senior figures in the Iranian regime. One person has been removed from Canada due to their ties to the Iranian government. Two others were declared inadmissible and issued deportation orders.
According to Global News, as of June 6, approximately 17,800 immigration applications were reviewed for possible links to the Iranian regime that could make applicants inadmissible to Canada. Immigration officials cancelled 131 visas, and the CBSA launched 115 investigations. A CBSA spokesperson said that out of those, 49 investigations have been completed. In those cases, the individuals were either not present in Canada or were determined not to be senior officials of the Iranian regime, and therefore not considered inadmissible. The remaining cases are still under investigation or are part of ongoing enforcement actions.
The 2022 sanctions aimed to bar tens of thousands of Iranian officials and IRGC members from entering Canada, but they did not go far enough. The IRGC was not listed as a terrorist organization until 2024. Unfortunately, lax immigration and visa policies allowed some IRGC members, their families and Iranian officials to obtain visas to enter Canada. In Canada (Minister of Public Safety and Emergency Preparedness) v. Iranmanesh, [2024] I.D.D. No. 79, on Feb. 2, 2024, the Immigration and Refugee Board ordered the deportation of a senior Iranian government official who served as director general of Iran’s vice-presidency for science and technology and entered Canada using a visa issued by the visa post in Turkey. This highlights serious flaws in the immigration system and national security controls.
While his removal marks a step forward, the fact that he remained in Canada for eight months before action was taken underscores a troubling failure in the screening process. This raises several critical questions: Why was a senior Iranian official granted a visa? The visa approval suggests either negligence by Immigration, Refugees and Citizenship Canada officers or serious gaps in security vetting. Also, if the CBSA only identified him after his arrival, it suggests that there was probably some derogatory information available to the authorities, but screening procedures are not effective in preventing inadmissible individuals from entering Canada; instead, they are reactive and take too long to be implemented. However, the sheer volume of ongoing investigations raises serious concerns about how Iranians with alleged ties to the regime continue to enter the country. Officials should have screened out the individuals before they arrived rather than dealing with their removal after the fact. Once someone enters Canada, deportation becomes a complex, lengthy and challenging process that can stretch for years.
As of March 6, 2025, the Government of Canada amended the Special Economic Measures (Iran) Regulations to expand the listing criteria beyond just the IRGC. The updated regulations now allow for the designation of any current or former senior Iranian government official where there is credible evidence of conduct that undermines international peace, security or stability, including Iran’s military support for Russia’s illegal war against Ukraine. While these amendments provide the framework that will allow the authorities to impose asset freezes, prohibit dealings and deem listed individuals inadmissible to Canada under the Immigration and Refugee Protection Act, their effectiveness depends on prompt action. Without immediate and proactive listings, the sanctions regime still offers no automatic barrier to travel or asylum claims, highlighting the need for faster and fuller implementation.
Former justice minister Irwin Cotler has expressed serious concerns that Iran may have activated sleeper cells in Canada to target critics of the regime, warning that close cooperation between Canadian intelligence and law enforcement is essential to prevent any infiltration. His concerns come amid increased scrutiny of Iranian activities in Canada, especially following Ottawa’s move last spring to join the United States in officially designating the IRGC as a terrorist group. Foreign Affairs Minister Anita Anand echoed these concerns, stating at a NATO summit in The Hague that the government is “very concerned” about possible Iranian state actions on Canadian soil.
Although the findings of the Public Inquiry Into Foreign Interference in Federal Electoral Processes and Democratic Institutions (Justice Marie-Josée Hogue, commissioner) found no evidence that Iran seeks to influence Canadian politics, it did reveal that the regime monitors and attempts to silence critics in the Iranian Canadian community. According to the report, some Iranian officials have entered Canada using false identities, and individuals with histories of human rights abuses in Iran are reportedly living freely in the country. Iran’s state-controlled banks have been repeatedly tied to financing terrorist groups like Hezbollah and Hamas, yet Canada has not explicitly barred Iranian financial executives or individuals linked to these institutions. Targeting regime officials while not including their financiers renders sanctions ineffective.
For years, bad actors have taken advantage of Canada’s lax security and immigration protocols. This pattern is not new. Individuals affiliated with designated terrorist organizations such as the Liberation Tigers of Tamil Eelam and the Popular Front for the Liberation of Palestine have previously sought refuge or secured permanent residency in Canada.
What sets the current situation involving Iranian officials apart is the apparent existence of a coordinated strategy to use Canada as a sanctuary. This trend poses a serious threat to public safety, especially to Iranian dissidents and human rights advocates residing in Canada, as well as to their families in Iran, who may face retaliation, imprisonment or even execution.
To safeguard its national security and uphold democratic values, Canada must adopt a more vigilant and proactive approach in screening and preventing the entry of nefarious actors. This includes not only members of the IRGC but also individuals linked to Iranian-sponsored terrorist organizations such as Hamas, Hezbollah, the Houthis and others. To effectively close existing gaps, Canada should impose stricter and broader immigration sanctions on all individuals associated with the Iranian regime, casting the net wide enough to eliminate loopholes. Enhanced screening for permanent residency and citizenship applications is essential, along with an expedited deportation process for those who have already entered the country under false pretenses.
Sergio R. Karas, principal of Karas Immigration Law Professional Corporation, is a certified specialist in Canadian Citizenship and Immigration Law by the Law Society of Ontario. He is co-chair of the ABA International Law Section Immigration and Naturalization Committee, past chair of the Ontario Bar Association Citizenship and Immigration Section, past chair of the International Bar Association Immigration and Nationality Committee, and a fellow of the American Bar Foundation. He can be reached at karas@karas.ca. The author is grateful for the contribution to this article by Jhanvi Katariya, student-at-law.
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