Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

Canada Appears to Increase Export Detentions of Goods Shipped to Iran and Dubai

Based on what we have been seeing lately from clients / exporters, the Canada Border Services Agency is detaining more shipments destined for Iran and Dubai. They are requesting addition information to ensure that the exporter has obtained the proper export permits from the Canada's Department of Foreign Affairs and International Trade, Export & Import Controls Bureau (EICB). We are seeing requests for information such as: (1) name of buyer, (2) location of buyer, (3) name of consignee, if any, (4)export permits, (5) technical information, (6) end use certifications, (7) certificates of origin (to ensure goods are not of U.S. origin), and (8) proof of payment / wire transfer / payment terms.

Shortly after the letter arrives from the Canada Border Services Agency, a letter is received from the EICB requesting similar information.

Based on the number of calls we have received lately, it appears that there is an unpublished policy that is being followed. As a result, exporters should exercise greater due diligence in determining:

(1) Whether their exported goods are prohibited by the United Nations Act (Canada) and Regulations Implementing the United Nations Resolution on Iran (or, in the case of Burma, Belarus, Cote d'Ivoire, North Korea, Democratic Republic of Congo, Iraq, Lebanon, Liberia, Rwanda, Sierra Leone, Somalia, Sudan, Zimbabwe, some other prohibition);

(2) Whether their exported goods are on Canada's Export Control List;

(3) Whether the goods are destined for Iran (or another country subject to export controls or embargoes or sanctions;

(4) Whether the goods are of U.S. origin and require an export permit from Canada or the United States;

(5) Whether the goods include more than 10% U.S. content;

(6) Whether the U.S export control laws would extra-territorially apply;

(7) Whether their Canadian Export Declaration is properly completed; and

(8) Whether their documentation is in order.

While the UAE is not a country against which Canada has sanctions or embargoes, exports to Dubai appear to be of concern because Dubai is a hub of trade to Iran. in short, it appears Canada is asking the questions as the goods are leaving to prevent controlled goods leaving without proper approvals.

If you have further questions, please ask Cyndee Todgham Cherniak at 416-307-4168.





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