The Canadian debate on foreign election meddling has focused almost exclusively on China. Some also want to investigate the interventions of other foreign governments. The foreign meddling debate in the United States is broader and encompasses powerful non-state actors, including foreign-influenced corporations.

The US debate is instructive and may help Canadians decide how broad the focus of a public inquiry should be if Parliament decides on one.

The call to go beyond enforcing bans on direct foreign government interference is being increasingly made in the US, where momentum is growing to prohibit indirect election meddling by domestic corporations appreciably owned by foreign investors. These foreign investors may be a sovereign wealth fund controlled by the Saudi government, a Russian oligarch, a Japanese or Chinese conglomerate, or Norway’s central bank, among countless others.

Allegations about Russia’s meddling in the 2016 US presidential election prompted Canada’s Parliament to pass the Elections Modernization Act two years later. The act forbids foreign third parties from participating in Canadian elections and incurring expenses for activities during pre-election and election periods. Yet, Elections Canada left a loophole as wide as a prairie sky.

According to the act, foreign entities include “corporations outside Canada.” But foreign-owned corporations that list their headquarters in Canada are not deemed to be foreign entities. This loophole must be probed. Most foreign-owned oil corporations for instance merrily wave the maple leaf flag and designate Calgary as their headquarters, but all the big ones are foreign-funded and foreign-influenced. Foreign-owned means foreign-funded.

Big Oil regularly intervenes in Canadian politics and does so with foreign money on a huge scale. Size matters. Setting up shop inside Canada has long been a way for foreign corporations to pose as Canadian.

In the United States, there is significant momentum on the local, state, and federal levels for laws to ban political spending by foreign-influenced companies. For example, in 2020, Seattle passed such a law, after a major foreign-influenced corporation spent approximately $1.5 million—a record breaking sum—in an attempt to help elect its preferred candidates to the city council.

Last month, Minnesota became the first state to pass this policy into law, with similar bills making their way through legislative chambers in several other states, including New York, Washington, and Hawaii. On the federal level, legislation authored by pro-democracy champion Rep. Jamie Raskin (D-MD) garnered 35 cosponsors.

US lawmakers point to the bedrock principle that the strength of a nation’s economy and security should be shaped by the nation. Foreign interests often diverge from domestic ones, especially in areas like national security, taxation, or energy production. That is why America’s founders—more than two centuries ago—warned against attempts by foreign entities to subvert the democratic process.

This subversion can take place via the corporate form, either directly or indirectly. As most people understand, CEOs are obligated to look out for the best interests of their shareholders. This includes foreign shareholders (who now own approximately 40 percent of US stock).

Notoriously, the former CEO of US-based ExxonMobil, which is substantially owned by foreign investors, once said, “I’m not a US company, and I don’t make decisions based on what’s good for the US.” It’s little wonder that lawmakers are increasingly supporting popular legislation to close the loophole that allows US-based, multinational companies to spend unlimited amounts of corporate money—including money derived from foreign investors—to sway the results of elections.

The debate in Canada needs to be broadened too. If there is a public inquiry, its terms of reference could encompass all forms of foreign political meddling, including from powerful non-state actors. As in other democratic countries, citizens alone must be able to choose their own government, free from outside influence.

Gordon Laxer is a political economist and professor emeritus at the University of Alberta.

Michael Sozan, a former chief of staff to a US senator, is a senior fellow at the Center for American Progress, a non-partisan policy institute based in Washington, DC, where he focuses his work on democracy reforms.

This article originally appeared in the Toronto Star.