I think it's a huge challenge elsewhere, not just in Canada.
First of all, Canada doesn't have the investigative or enforcement capabilities that the Office of Foreign Assets Control in the U.S. Treasury has. There, the staffing is in the hundreds of people, and the sophistication of the techniques they use has also been honed over many years.
I think that is the first point. Having the proper ability to conduct investigations and to engage in enforcement is critical. At the moment, I believe all of this—decisions on new sanctions and outreach to private sector investigations—is done by a small group within Global Affairs Canada. They simply can't do everything. I would say that really warrants some closer capacity if that is to change.
Another lesson is that working with partners is really key. It's not for no reason that we see the special envoys of the U.S. and the EU, Jim O’Brien and David O’Sullivan, working together to encourage third countries to clamp down on circumvention, or to not, at least, support evasion and so on. It is also key, working with international partners.
A final point I would make is that capacity in third countries is absolutely critical. Many of the countries you'd hope are helping not to fill gaps, or at least to help enforce sanctions, may be really lacking in capacity. That's not just in the government department, but also customs, the intelligence services, policing and so on.
There really need to be some very serious capacity-building efforts overseas that could be done collectively with other partners.