Yes. One of the great benefits of the legislative process called Bill C-47, leading to Canada's welcome accession to the Arms Trade Treaty, was the substantial risk clause and the two words “shall not”. As a result of this inclusion of the substantial risk clause, it is not optional.
It used to be that the government had an obligation to consider certain factors, but as long as the factors were considered, the minister could basically authorize exports anywhere. Now, the minister has a legal obligation. If a human rights trigger is identified, then the minister “shall not” authorize those shipments. We are in a stronger position now, because the minister, again, has the obligation to deny certain export permits.
The extent to which this will continue to be implemented remains to be seen.