Canada has three sanctions regimes. We have the Justice for Victims of Corrupt Foreign Officials Act, which is often referred to as the Magnitsky regime. We have the Special Economic Measures Act and we have the United Nations Act.
I won't dwell on the UN Act. This is the act under which we are empowered to enact any sanctions that are imposed by the United Nations Security Council, as we are legally obligated to do as a UN member.
The difference between the Justice for Victims of Corrupt Foreign Officials Act and SEMA is.... There's some overlap, but there are real differences.
I will put it this way: The Justice for Victims of Corrupt Foreign Officials Act is limited to individuals, and it is related exclusively to human rights and corruption. SEMA can also enable us to level sanctions on individuals and also has a human rights trigger; however, under SEMA, Canada can also sanction a state and can apply some prohibitions at the state level. It can also sanction entities as well as institutions, so states, their institutions, organizations, businesses and large outfits like that. Where the JVCFOA is limited to individuals, SEMA has a variety of provisions that allow us to target either individuals, entities, or even states.
As the member has correctly noted, the Justice for Victims of Corrupt Foreign Officials Act has a human rights trigger and a corruption trigger. In SEMA we also have an international peace and security trigger. A grave breach of international peace and security that is likely to result in a serious international crisis is grounds under SEMA for initiating—