As you said, this would raise very complicated and very difficult issues. For the purpose of simplicity, I will assume there has been no co-operation with a Canadian party or player, so we have a Chinese company on its own doing that. First, it becomes very difficult to investigate, as you suggested. Second, even assuming you could get the information you needed to proceed with a charge, I would think the only thing you could contemplate doing, based on the wording of the legislation as it is now, would be essentially to lay a charge in Canada. If the company has some presence in Canada now or at some point in time, you could take them to court and perhaps do something with respect to their assets if they were convicted. However, if they operate only outside of Canada—in China, in the example you use—it is extremely difficult to enforce the legislation in circumstances like this.
On June 8th, 2017. See this statement in context.