Thank you for that question. It's good to see you again.
The assertion that Canada has one of the most robust systems is false. There is a loophole the size of a bus in our implementing legislation, and that concerns exports to the United States. Right there is a fatal flaw in that assertion.
Second, the actual implementing legislation does not completely fulfill the Arms Trade Treaty. They keep talking about substantial risk. Substantial risk is not the language used in the Arms Trade Treaty. You're required to take mitigating measures, and if there's an overriding risk in terms of those mitigation measures' being insufficient, then you can't export. So, it's not substantial risk; it's whether you can mitigate or not, whether you can eliminate risk. Even there the department is putting forward a bit of a misrepresentation as to what Canada's international legal obligations are.
But then, as I said in my introductory remarks, the department has gone on to apply the implementing legislation as narrowly as possible. For instance, it's arguing that these targeting systems will make a widget on the side of a naval ship when, in fact, they're the core of the system. It's narrowing the geographic and temporal scope. In other words, it's trying to balance the economic incentive for exports against the implementing legislation and is consistently failing to get it right.