General permit issued under the Special Economic Measures Act: Syria - Frequently Asked Questions

On this page

• General permits
• "Individual permit” versus “general permit”
• Who can use and access a general permit
• Activities allowed under the General Permit (Syria)
• Activities that are not allowed under the General Permit (Syria)
• Validity period of the General Permit (Syria)
• Obligations when using and accessing the General Permit (Syria)

General permits

Issued under the Special Economic Measures Permit Authorization Order, a general permit allows, during the permit’s validity period, any person in Canada and all Canadians abroad to carry out activities or class(es) of activity or transactions specified in the general permit, that would otherwise be prohibited by the Special Economic Measures Act (the “Act”) or any order or regulations made under the Act. Persons wishing to conduct activities or transactions within the scope of a general permit do not need to apply for an individual permit from the Minister of Foreign Affairs.

Persons (individuals or entities) seeking to engage in activities or transactions pursuant to a general permit must first make sure the activities or transactions they wish to undertake fall within the scope and validity period of the general permit.

"Individual permit” versus “general permit”

An “individual permit” allows a specific person (individual or entity) to do a particular activity or transaction, or class of activity or transaction, that would normally be prohibited under the Special Economic Measures Act or any order or regulations made under the Act. This type of permit requires that an individual permit application first be submitted to the Sanctions Bureau of Global Affairs Canada.

• Information on how to apply, and what documents are required, to complete an application for an individual permit is available on the Permit and certificates page.
• Please note that Global Affairs Canada cannot provide legal advice to the public and thus is not in a position to confirm whether an intended activity or transaction would require that you first submit an application for an individual permit from the Minister of Foreign Affairs.

A “general permit” allows, during a specified period, any person in Canada and Canadians abroad to carry out a specified activity or transaction, or class of activity and transactions, that would otherwise be prohibited by the Special Economic Measures Act or any order or regulations made under the Act. Contrary to an individual permit, persons do not need to submit an application to the Minister of Foreign Affairs before being allowed to carry out activities or transactions that are within the general permit’s scope and validity period.

The Minister of Foreign Affairs has the authority to issue both individual permits and general permits subject to any terms and conditions that are, in the opinion of the Minister, consistent with the Special Economic Measures Act and any order or regulations made under the Act.

Permits allow for a specific set of activities or transactions that would otherwise be prohibited by sanctions regulations to be carried out for the duration of the permit’s validity period.

Who can use and access a general permit

A general permit can be used and accessed by any person in Canada and Canadians outside Canada.

Activities allowed under the General Permit (Syria)

On February 27, 2025, the Minister of Foreign affairs issued a Ministerial Order titled General Permit Allowing Specified Activities that Are Prohibited Under the Special Economic Measures (Syria) Regulations (the General Permit (Syria) (the “General Permit (Syria)”).

According to this Ministerial Order, the General Permit (Syria) allows any person in Canada or Canadians abroad to carry out, for a period of six months, certain activities and transactions that are otherwise prohibited under the Special Economic Measures (Syria) Regulations (“the Syria Regulations”).

Specifically, until August 25, 2025, any person in Canada and Canadians outside of Canada may provide any financial or related services to or within Syria, in support of democratization, stabilization and the delivery of humanitarian assistance to or within Syria, including by taking part in transactions where the following seven (7) Syrian banks currently listed under the Syria Regulations are involved:

1. Commercial Bank of Syria
2. Real Estate Bank
3. Industrial Bank
4. Popular Credit Bank
5. Saving Bank
6. Agricultural Cooperative Bank
7. Central Bank of Syria

Activities related to the delivery of humanitarian assistance could include, but are not limited to:

• Assistance that seeks to save lives and alleviate suffering of a crisis-affected population, including actions that, within a short time span, remedy, mitigate or avert direct loss of life and harm to people, and protect their dignity, as defined in the CERF Life Saving Criteria.
  • This could include but is not limited to:
    • food and non-food items
    • emergency medical services to treat life or limb-threatening situations
    • nutrition services
    • shelter
    • water
    • sanitation
    • hygiene, and
    • protection
  • Common support services that are necessary to enable life-saving activities to be carried out (for example, logistics, including supply chain management, transportation of aid, including the use of aircraft and/or ships, camp management, emergency telecommunications, technical supervision, training, monitoring, and evaluation of programming, etc.).
  • Transactions necessary and incidental to carrying out humanitarian activities or supporting humanitarian organizations (for example, administrative transactions such as the payment of staff and contractor salaries, maintenance of bank accounts, duties and other fees, taxes, licences, etc.)

Activities that are not allowed under the General Permit (Syria)

Persons in Canada and Canadians outside Canada are prohibited from dealing in the property of, entering into transactions with, providing services to, transferring property to, or otherwise making goods available to listed individuals and entities under the Syria Regulations, with the exception of transactions effected through the seven aforementioned Syrian banks made in support of democratization, stabilization and the delivery of humanitarian assistance to or within Syria.

Persons (individuals and entities) wishing to undertake activities or transactions prohibited under the Syria Regulations falling outside the scope of the General Permit (Syria) must still apply for an individual permit to the Minister of Foreign Affairs. Please note that Global Affairs Canada cannot provide legal advice to the public and thus is not in a position to confirm whether an intended activity or transaction would require that you first submit an application for an individual permit from the Minister of Foreign Affairs.

Validity period of the General Permit (Syria)

The General Permit (Syria) is valid for a period of 6 months from the date of its entry into force, in other words, from February 27, 2025, to August 25, 2025.

Obligations when using and accessing the General Permit (Syria)

It is the responsibility of any person using the General Permit (Syria) to ensure the activities or transactions they undertake fall within the scope of the General Permit (Syria).

Contravening the terms and conditions of a general permit is a criminal offence. Criminal offences are investigated and enforced by the Canada Border Services Agency and the Royal Canadian Mounted Police. Under the Special Economic Measures Act, the maximum penalty on summary conviction is a $25,000 fine or a 1‑year prison term, or both. Conviction on indictment may result in a maximum 5‑year prison term.

Persons in Canada and Canadians abroad are also required to comply with several other Canadian laws that restrict or impose limits on certain activities with foreign states or foreign nationals. It is the responsibility of any person (individual or entity) intending to undertake activities or transactions pursuant to the General Permit (Syria) to first ensure that they are diligently informing themselves of their legal obligations and, if appropriate, that they are taking steps to obtain any other legally required certificates or authorizations before initiating their intended activities or transactions.

Alongside the General Permit (Syria), persons may also be required to apply separately for an authorization under the Criminal Code Authorization Regime to be able to undertake their activity or transaction in Syria as there could be a risk of criminal liability under 83.03(2) of the Criminal Code. While it is a criminal offence to directly or indirectly provide property or other financial or related services to a terrorist group, criminal liability for an unavoidable benefit to a terrorist group may be shielded by an authorization in certain circumstances. For more information on eligibility and how to apply for this authorization, see Authorization regime and humanitarian exception for activities in terrorist group controlled areas - Section 83.03 Criminal Code.

Should you need assistance in interpreting Canadian sanctions regulations, it is suggested that you seek the advice of private legal counsel.