Thank you very much.
I'm pleased to be here today.
My starting point is that Canada does not do enough to counter IRGC activities inside the country here. Committee members, I think, are well aware of the nature of IRGC activities, especially in terms of transnational repression, the presence of senior regime members or their families, the parking of financial assets and so on.
To better counter IRGC activities in Canada, a combination of targeted measures should be the way forward. I understand the symbolic politics of listing the IRGC as a terrorist entity under the Criminal Code. I am especially sensitive to pleas from victims of IRGC repression or brutality, and from family members of victims, but the most ethical response to the IRGC's activities here is an effective one, a response that targets those doing the most harm and that best protects the victims.
To situate my thinking, I would emphasize that I don't view this issue through a Iran lens specifically, but through the broader prism of Canada's overall security priorities and policies. This broader perspective emphasises two factors.
One is that Canada faces a deteriorating security environment today, with multiple and intensifying threats. IRGC activities represent one of these threats, but they're not the only one, and I would say it's not the top one. The other is that our security and intelligence agencies today are already vastly overstretched and under-resourced. That's the broader context.
Listing the IRGC as a terrorist entity under the Criminal Code would be very labour-intensive. There are hundreds of thousands of current and former members. Enforcing this would be very demanding for law enforcement and national security agencies. It also raises the risk that innocents can be caught in the sweeping net of broad sanctions. This has become a serious problem in the U.S.
To counter this problem, several people will suggest exemptions whereby only those, for example, with blood on their hands or above a certain rank would be sanctioned. This is appealing in theory, but in practice it further increases the workload of already overstretched agencies.
This is a serious problem, even if it's one that is easy to dismiss. Canada already cannot fulfill our existing commitments to monitor and enforce current sanctions, let alone new ones. It is important to emphasize how much this irritates our allies. It is an increasingly serious problem that we underestimate, and it is one that goes beyond only sanctions to national security and defence in general. It also sends a message to adversaries that we are not serious about penalizing them and that we care only about the domestic politics of it, not about actually enforcing concrete measures.
In the reality we live in of scarce resources, proponents of listing the IRGC should explain which threats our national security agencies should stop focusing on as they redirect energies toward managing the listing of the IRGC and how this would make Canada more secure overall.
Proponents often answer by suggesting that the government should simply increase the resources of national security and law enforcement agencies. This is valid in general terms, but does not support the argument in practice. IRGC activities are only one of the many threats that our national security agencies struggle to counter. It is not clear why eventual additional resources should be targeted at the IRGC as opposed to what I think are the bigger threats coming in particular from China and several others.
I would also add that my colleagues who are lawyers question the lawfulness of listing the IRGC, which is the armed forces of a state, on a list that is meant for non-state actors. Not being a lawyer myself, I'm not in a position to expand on this point, but I would encourage the committee to look further into it.
My suggestion to the committee, as we try to find the most effective way to better counter IRGC activities in Canada, is to focus on targeted measures, and more specifically on five initiatives.
The first is to fully implement and enforce measures that we have already adopted, notably under the Special Economic Measures Act and the Immigration and Refugee Protection Act, which, as I said, we are not fully enforcing as it is.
The second is to consider adding more individuals and entities under SEMA and IRPA, and making greater use of other tools, such as corruption investigations. We could also better target Hezbollah financial networks here in Canada. The reality is that we are not fully exploiting the more surgical tools at our disposal.
To do that, the third initiative is that we need is to provide our national security intelligence and law enforcement agencies and departments with more resources to enforce and monitor sanctions. I cannot emphasize enough how badly overstretched they currently are.
The fourth is that we could also improve coordination and information sharing among the many departments and agencies involved in the development and enforcement of sanctions.
The fifth, and I will finish on this, is that we could also enhance transparency on sanctions and their enforcement. This would allow for more accountability and better scrutiny by civil society, by Parliament and by the media, including scrutiny of the fact that we are a poor performer on the sanctions enforcement front.
We also need to be more transparent about what we aim to achieve with sanctions, and whether we are achieving it or not.
Thank you.