What I would say is that Canada has gone above and beyond by putting it into legislation, as opposed to regulation. That nuance is simply that most countries would put it into regulation, which would allow them to be slightly more flexible over time in how they transform or modify, if need be, their standards, specifically their legal terms and their understanding of the application of the UN ATT.
That said, we have waited for quite some time to find ourselves in possession of documents—and I would say that it is this committee that has caused the release of these documents—that have crystallized what the terms are and what uses the government will apply to terms such as “substantial risk” and “mitigating measures”. These criteria need to be defined and then applied by each government entity.
During the period 2017 to 2021—where we are now—the definitions of what the government would look at in terms of “substantial risk” were opaque to us. I would argue, in fact, that as each instance of an export control issue gets raised, these definitions seem either to get clearer or get murkier, depending on what has occurred within the country.