Canada is not alone in this issue and problem. A few years ago we organized a meeting between the panel of experts for the Lybia sanctions committee here in Geneva and private sector individuals, because as the first speaker has pointed out, individual financial firms are themselves the main sources of the implementation of these measures.
The comments we heard from the private sector—from financial institutions, from insurance companies, from shipping companies—were about the inadequate information they were receiving from their governments. Particularly, I must say—this seemed to be disproportionately from the U.K.—there were complaints about Brussels. I'm not going to make a Brexit comment at this point, but it's a common problem that the private sector has difficulty getting the information it needs in a timely manner. This is not a uniquely Canadian problem. It's a problem for the private sector implementing sanctions globally.
I made reference in my comments to the challenge of keeping targeted sanctions targeted. This is keeping them consistent with the careful design of the measures, when they are actually being crafted in New York, Brussels, or Ottawa. I think the problem of keeping them targeted is a problem of what we call the dual translation problem. There are two translations that are under way: first, the translation from, in the case of the EU, a council decision, or in the case of the UN, a Security Council resolution, into national legislation; and second, the communication of that national legislation to the private sector.
At both of these points, the translation—from a council decision to government legislation, and to the interpretation of that legislation, the way it's communicated to firms and the way firms then through compliance implement the measures—can lead to a significant distortion. It could mean a narrowing, but most often it means a widening or broadening of the sanctions and particularly over Iran in the past few years, the phenomenon of widespread derisking because firms were simply concerned that if they didn't divest virtually all activities with regard to Iran, they could be in trouble with their own governments, and with other governments as well in terms of fines and penalties.