Here is the definition of Foreign Interference in the Act. It seems pretty clear to me that it applies.
“Foreign interference in the Canadian electoral process can pose a serious threat to our democracy. All allegations of
wrongdoing on the part of a foreign person or entity are taken seriously and are carefully examined to determine
whether they fall within the Commissioner's mandate.
• Undue influence by foreigners
**** Foreign persons or entities are prohibited from unduly influencing a Canadian elector to vote or refrain from voting, or to vote or refrain from voting for a particular candidate or registered party. *****
Examples of undue influence may include an individual who does not reside in Canada who is neither a Canadian citizen nor a permanent resident knowingly incurring expenses that directly promote or oppose:
• a candidate in an election;
• a registered party that has endorsed a candidate in that election; or
• the leader of such a registered party.
It may also include attempts to influence the elector that involve committing an act or omission that is contrary to federal or provincial laws and regulations.”