It's a good point. Our Belarus measures are export controls. They're not economic sanctions. What the U.S. did with Belarus was in large part a list-based sanctions measure. They identified certain parties you couldn't do business with related to Belarus and the Belarus government. In the case of Canada, it was an export control. It didn't really restrict Canadians who were abroad from doing business with Belarus.
However, it was a very aggressive export control. To put a country on the area control list is a massive step, I think. We did it with respect to Burma. North Korea is on that list right now. When Belarus was on it, it meant no exports could go to Belarus. It also meant that no technology transfers could occur, and that tripped up a lot of Canadian companies. Belarus used to be a kind of silicon valley of the old Soviet Union. There are a lot of legacy operations there with computer producers and software developers. There are many software companies in Canada that had been working with software developers in Belarus, and they unknowingly got offside when they were transferring technology to Belarus as part of that software development.
I wouldn't characterize the measures from the United States or the EU as more aggressive, necessarily; they're different. But I can tell you that putting Belarus on the area control list presented a very difficult situation for Canadians and for Canadian subsidiaries of U.S. companies, because the U.S. didn't implement a measure like that. Many U.S. companies weren't aware that Canada had this measure in place. Their Canadian operations may have gone ahead and done business with Belarus because of that.
A large part of my practice is just what you've identified, which is situations in which the U.S. and Canada are not completely aligned on sanctions measures, and with the EU or Australia and other countries. That creates a lot of difficulty for Canadian companies.
From a policy point of view, I think it's a bit of a different issue. From a policy point of view you may decide that you want to be aligned. It is much easier for Canadian businesses, if we're completely aligned, but that's no longer a made-in-Canada policy. It requires us to align ourselves with the U.S.—I don't think you'd see the reverse case, in which the U.S. would necessarily align themselves with our policies—but it's a more challenging prospect, because I'm not sure it's always the best Canadian policy to just do what the Americans are doing. If that were the case, we'd have no success in Cuba right now.