Foreign Affairs Committee on Feb. 3rd, 2026

[Robert Brookfield]

First, to clarify a point, the Export and Import Permits Act is not our primary legislation for dealing with sanctions against Russia. That's primarily the Special Economic Measures Act, which has prohibitions on exportation and other dealings prohibitions. It is a different regulatory regime.

It's true that under the Export and Import Permits Act we do have a policy of presumptive denial for controlled goods to Russia, but they are not, for example, on the area control list, which is another sanctions-like mechanism under the Export and Import Permits Act. To clarify that point, that's not the legislation that is before this committee, as I understand it.

I'm sorry. I think I missed the second part of your question.

[Jacob Mantle, Conservative, York—Durham, ON]

Your KPIs for the—

[Robert Brookfield]

Under the Export and Import Permits Act, one of our primary KPIs is a question of service standards. As required under section 27 of the Export and Import Permits Act, we provide a report to Parliament every May on group 2 exported goods—military goods, essentially. That sets out the extent to which we are meeting our service standards.

Our service standard is essentially that we will provide a decision on a permit to NATO Plus countries, such as Japan and South Korea, within 10 days of application, and within 40 days for other countries.

[Jacob Mantle, Conservative, York—Durham, ON]

Do any of your KPIs refer to referral to the RCMP for potential violations?

[Robert Brookfield]

I'm a bit confused by the question. Our desire and our system is structured to prevent violations.

As I mentioned earlier, most Canadian companies, most individuals in Canada—

[Jacob Mantle, Conservative, York—Durham, ON]

I think that in Canada—

[Robert Brookfield]

If I may finish, most individuals in Canada want to comply with the law. Our focus is on helping them to comply with the law. We would not want the status of our system to be measured by how many people violate it. We want to prevent them from violating it, and most of them don't want to violate it.

[Jacob Mantle, Conservative, York—Durham, ON]

I would suggest to you that violations are rampant and well documented. For example, Canadian-made electronic detonators that were exported to Kyrgyzstan were re-exported to Russia, and over 30 Canadian luxury jets have been exported to Russia since the war began.

I don't think it's reasonable or persuasive to suggest that because we have this regime, everybody follows it. I think Canada actually has a reputation for being a paper tiger. When I taught a course at Queen's law on this, that was one of my exam questions.

In the last 30 seconds, I'll give you the exam question and you can give me your answer. The question was, do you think Canada's export and import controls and sanctions are a paper tiger?

[The Hon. Steven Guilbeault, Liberal, Steven Guilbeault]

Mr. Chair, I think that’s completely inappropriate.

[The Hon. Mona Fortier, Liberal, Mona Fortier]

That’s so inappropriate, Mr. Chair. I raise a point of order.

[Jacob Mantle, Conservative, York—Durham, ON]

Yes, they were.

Give me your top-level thoughts on that.

[Robert Brookfield]

I'm not aware of the specific examples you gave. I will say, as a general point, that we look very carefully into any allegations of problems and we do try to make sure that they are prosecuted and addressed.

There are challenges with prosecutions. At the end of the day, it's for independent police to do the best they can with the evidence they have to bring prosecutors a case that could be prosecuted. A case must meet the criminal standard in order to be able to bring a challenge. That's not our department's responsibility, but we do support them in doing so.

[The Chair, Liberal, Ahmed Hussen]

Thank you very much.

Next we go to MP Rob Oliphant.

You have five minutes.

[Rob Oliphant, Liberal, Don Valley West, ON]

Thank you. I don't think I'll need all that. I think the officials have done a very good job at explaining the regimes to us.

I just want to take a moment to thank you for the work you do. In the number of sanctions that have been imposed, beginning with Venezuela as the first surge of sanctions and then with Russia, we have broken all records in the amount of work that you have had to do.

I also want to thank you for what has proven to be an incredible incentive for Canadian businesses to comply. You get many questions, I am sure, from exporters who would like to sell something but check it out first so that they are in compliance with the law. I am assuming that is far more of your work than is acknowledged publicly, so thank you for your work, and we'll see what comes in the next round of legislative changes that could happen in the future. Thank you very much.

[The Chair, Liberal, Ahmed Hussen]

Would you like to respond to any of those comments?

[Robert Brookfield]

Thank you for your kind words.

[The Chair, Liberal, Ahmed Hussen]

Officials, thank you very much for your patience and your testimony in front of this committee. Thank you for being here today.

That brings us, colleagues, to the end of the meeting. Is it the will of the committee to adjourn the meeting?

[Some hon. members]

Agreed.

[The Chair, Liberal, Ahmed Hussen]

Thank you. The meeting is adjourned.