As I mentioned earlier to your colleague, I cannot speak about any specific Canadian company or specific case. I can speak about the elements of Bill C-47 and the establishment of a brokering regime, which would create the requirement for any Canadian citizen, permanent resident, or organization registered in Canada to apply for a permit in order to arrange or negotiate the movement of a controlled item from a foreign country to another foreign country. The regulations will provide further precision on how we define certain types of transactions if there are certain things that we would wish to exclude.
For example, we very likely will apply general brokering permits to certain types of transactions. The principle being that we can apply the very valuable resources that are afforded to us by government for the administration of the program, we want to focus on the highest-risk transactions and not use the resources to assess transactions that are likely to be of low risk. What will be critical in assessing any particular case is to look at the person or covered organization that is the directing mind: those responsible for the transaction.
Organizations and companies that are not registered in Canada will not be covered by Canadian law. That would be an extraterritorial reach that would be inappropriate, or at least not consistent with how Canadian law is usually applied.