Thank you for the question.
With respect to definitions, it's important that it's not only about the Special Economic Measures Act. If you look at paragraph 35(1)(c) of the IRPA as it exists today, it doesn't actually limit the imposition of sanctions to that one act. For instance, there's also the United Nations Act, which is used to impose some United Nations Security Council sanctions and travel bans.
If you're looking at definitional requirements, it's best to place those, in our view, in the statutes that have the authorities to generate those sanctions to begin with, and not in the Immigration and Refugee Protection Act.