That's a good question.
I think the provision you're talking about is in the model legislation. This was, in particular, to protect banks. When you freeze assets and you're relying on the government's action, they get what's called a “safe harbour” from being sued. That has been an important measure in terms of banks being able to implement sanctions.
Now it's far more complicated. You had sovereign wealth funds, for example, that we went after in the context of Libya. I think what it argues for is this. You can put in place sanctions, but there are exemptions. There is a process both with unilateral sanctions, I would imagine, that Canada has with the U.S.... Even in the context of UN sanctions, there are exemptions. There are exceptions that you can go to the committee.... In the case of Libya, they were almost overwhelmed with the number of requests for exemptions, because the sanctions were so broad.
Again, it's complicated. There is no easy answer. They have to actually be tailored to the specific circumstances and allow for some flexibility, but not so much so that each individual country is interpreting entirely on its own.
I don't know if that addresses your question. I'd be happy to go back and look at the provisions you're talking about in Interlaken and provide some additional information.