Yes, but I can't say with certainty without looking very closely at detailed circumstances.
I've mentioned, for example, a flight that arrived from Prague at the Toronto airport in May 2009, on which there were over a hundred people who made immediate asylum claims. All of the claims were almost identical. They were clearly coached and organized. That would be the kind of evidence that would lead to an assessment as a smuggling event.
Similarly, we've had cases of so-called “coyotes” bringing sometimes dozens of illegal immigrants across the land border, typically the Vermont-Quebec border, going through back roads and through the forests for a fee. These are smugglers. It's similar to what's happening in the U.S.-Mexico border.
So it wouldn't just be marine arrivals; there could also be terrestrial or air arrivals.