Thank you, Chair.
Thank you, MP Julian, for the question.
In reverse—on your second question—the provision as drafted has a degree of flexibility in it to recognize that there may be non-state entities that could still be sanctioned. Under paragraph (a) for example, you could still have the sanctioning of specific individuals or entities—news businesses—independent of where their headquarters are. Then paragraph (b) recognizes or is grounded in a question of where the headquarters are. My read is that there's a degree of flexibility there.
Just to give this committee an example, RT, Sputnik and certain other Russian media are currently specifically listed in the special economic measures sanctions. I don't have a non-state example for you, MP Julian.
With respect to your first question, we did have an opportunity to look into this. The way the sanctions are articulated is that they recognize that there are certain areas of Ukraine that are currently under Russian control, such as Crimea, so the sanctions are grounded in that territorial control of specific regions. Our read would be that, if you had a Ukrainian broadcaster, for example, operating in the free part of Ukraine, it would not be caught by that because the sanctions are quite specific that the only sanctioned entities are those based in or operating out of, for example, Russian-controlled areas of Ukraine.
I would also just simply remind the committee that, in addition, you would have to meet the other criteria in clause 27 in order to be eligible in the first place. That includes operating here in Canada, having two journalists, etc. It's just a reminder that there also has to be that presence here in Canada.