Foreign Affairs committee  We're not aware that the problem continues. I think, in part, the challenge in 2012 had to do with a lack of guidance from Global Affairs Canada on the interpretation of some of those sanctions. That's why it's so important either to have written guidance or to make sure we have ongoing discussions and dialogue with Global Affairs Canada to assist in avoiding those kinds of problems in the future.

Foreign Affairs committee  That's a bit challenging. A lot of it is diplomatic, isn't it? I think the focus on those jurisdictions—not necessarily the G20, but.... We know there are jurisdictions that are sanctions evaders, like the UAE. We're seeing potential transactions through India and through China.

Foreign Affairs committee  Thank you, Angelina. Mr. Chair and members, effectively, we're removing some of the largest Russian banks from SWIFT. It has choked off any transactions. Most of the Canadian banks no longer have direct access to Russia in terms of facilitating payments. It's had a good effect in the sense that it has denied some of the largest banks, like VEB, VTB and Sberbank access to western capital, but it has had unintended consequences for ordinary Canadians, and that's part of the reason for a lot of the permit applications to Global Affairs Canada.

Foreign Affairs committee  Yes. In China, there's the CIPS system, and Russia has SPFS. In terms of the rise, we haven't seen significant traffic in that regard, but I think that in terms of alternatives to SWIFT they are on the rise, and there is certainly that risk of capital flight away from that system.

Foreign Affairs committee  Interpretative guidance would assist. As an example, if you look at the United States and OFAC, they have something like 1,300 FAQs that have been published. Some of the interpretation around the proposed Bill C-47 is looking at changing beneficial ownership, but rather than using an OFAC 50% plus one rule, they have elected to go even further than the EU and the U.K., so it's really going to make it complicated when you look at the control test they're suggesting.