Yes, that's a very fair point. There is no expressed definition in the act, but as with any legislation, a term is going to be interpreted, having regard to its purpose and context.
The purpose and context here is all about implementing multilateral sanctions, primarily United Nations Security Council resolutions. To be clear, there are 15 United Nations Security Council resolutions right now that impose sanctions. Of those 15, it's absolutely crystal clear that 11 of them are sanctions against countries. There's no doubt that those 11 sanctions are imposed against countries and, thus, would trigger paragraph 35(1)(c) as it currently exists, or proposed paragraph 35.1(1)(a) as it would be amended by Bill S-8.