Alberta-based Lee Specialities Ltd. ("Lee") recently
pleaded guilty to a charge of exporting controlled goods to Iran,
in contravention of the Special Economic Measures (Iran)
Regulations (the "Iran Regulations" or
"Regulations") adopted under the Special Economic
Measures Act ("SEMA"). This is the first time that a
conviction has been obtained pursuant to SEMA.
In an agreed statement of facts filed with the Provincial
Court of Alberta on April 14, 2014, Lee admitted liability under
the Regulations for having attempted to ship certain controlled
goods to Iran without a Ministerial permit. Pursuant to a plea
bargain, Lee will pay a fine of $90,000.
This alert provides a brief overview of the facts
surrounding the conviction, an overview of the sanctions, and
lessons for Canadian companies.