Thank you.
The first thing I would say before I get to the comparison of Canada with other countries is that in regard to the test under national security under the act, the words “national security” are not defined, and that's to take into account the evolving nature of national security threats and the inability to draw a bright line somewhere.
However, the government has international trade obligations, and under its international trade obligations--WTO and NAFTA--there is an exception for measures that allow governments to treat parties that are non-nationals differently than they treat individuals domestically. It's under those provisions that you can have measures to protect national security. These trade agreements do define “national security”, so there are limitations, and the government has to be mindful to apply the act in a way that is consistent with the definitions under the acts.
With regard to the practices in other countries, there are two main points to consider here. Canada is one of the few countries that has a formal review mechanism of general applicability that extends to matters that are primarily economic in nature. That doesn't mean that in other countries there are no other laws or other instruments by which mergers may or may not be easier. I'm not going into other things related to crossover ownership of institutional banks and companies or anything like that. I won't go into that.
I think only two other countries in the world have similar mechanisms: laws of general applicability that apply across sectors. That being said, there are a lot of other countries that do have review mechanisms for transactions that are reviewed on the basis of national security. In fact, before the amendments to the act in 2009, Canada was the only one of the G-7 countries that did not have some form of mechanism that provided them with the authority to review transactions on national security grounds. So in that sense, it was more common on national security grounds.