But a difference nonetheless.

You can do your own homework on fraudulent conveyance/fraudulent preference -- there's plenty of Canadian jurisprudence on it.

As to getting the judgment recognized by a Canadian court and enforced (which I do happen have some experience and success in), the hurdles in the Speer's case will be:

1.  It's a default judgment.  Khadr and his counsel didn't defend against it, so the courts here will require arguments from Speer's side before agreeing to recognize it.

2.  The amount of the judgment for what it is -- $134M has no comparators in the Canadian system

3.  Evaluating Khadr's involvement in the wrongful death of Speer.  The court might not automatically accept the murder conviction (even though it is currently recognized in the Canadian court system) based on the Gitmo debacle, but could accept based on a balance of probabilities (civil standard).

2 & 3 need to be shown as not being wildly out of line/offensive to Canadian policy.