Former media baron Conrad Black cannot return to Canada just yet, the judge overseeing his bail hearing in Chicago has ruled.

At a hearing Friday to finalize the conditions of Black's bail, U.S. District Court Judge Amy St. Eve said the financial affidavit Black provided is insufficient and ordered him to reappear in her courtroom with more details on Aug. 16.

A court sketch shows Conrad Black, third from left, and his lawyers in a Chicago courtroom Friday. (Cheryl A. Cook)Until then, Black will not be allowed to leave the United States.

On Wednesday, St. Eve ordered that the Montreal-born Black be released from the Florida prison where he was incarcerated on fraud and obstruction charges, but said he could not leave the United States.

He was released on a $2-million US bond, paid by friend and business associate Roger Hertog. That amount, much less than the $25-million bail posted prior to his 2007 fraud convictions, is significant, trial lawyer and legal expert Terry Sullivan said.

"For all practical purposes, he's less of a risk now," he said.

Black's legal team argued again Friday that he should be allowed to return to his home in Toronto while he is out on bail.

Black's lawyer, Miguel Estrada, said the Florida home that the Blacks have access to is a bad residence for them in part because of certain health issues for his wife, Barbara Amiel.

Former media mogul Conrad Black arrives at the federal courthouse in Chicago with his wife, Barbara Amiel, on Friday. (Charles Rex Arbogast/Associated Press)Black provided the court with an account of his financial situation, which includes real estate and financial assets. But prosecutor Julie Porter said the document was too vague, and St. Eve, who sentenced Black to 6½ years in prison in 2007, agreed.

Some experts suggest that may only be temporary.

"Very seldomly is a case reversed by the Supreme Court of the U.S." Sullivan said. "They've pretty much gutted the case against Conrad Black."

More legal woes

U.S. officials say he owes $71 million in back taxes and there are various civil lawsuits against him.

Black was convicted of absconding with $6 million while he was in charge of now-defunct newspaper operator Hollinger International Inc.

Black leaves the courthouse in Chicago on Friday after being told he cannot leave the U.S. while on bail. (CBC)In June, the U.S. Supreme Court narrowed the scope of the "honest services" law under which Black was convicted on three counts of fraud.

The fraud convictions are now back before a U.S. federal appeals court, which will decide if they should be upheld or thrown out.

When proceedings finished on Friday afternoon, Black left the courtroom without speaking to reporters, hand in hand with Amiel.

Even if Black is ultimately allowed to leave the United States, it's unclear whether he would be allowed to return to Canada, where he owns a home in Toronto's tony Bridle Path neighbourhood.

His fraud convictions are up in the air, but his conviction on obstruction of justice remains in place. He is also not a Canadian citizen anymore, having famously renounced it to accept a British peerage, so he would need special permission — either an extradition agreement or ministerial order — to return to Canada.

Jason Kenney, Canada's minister of citizenship and immigration, said the department will not comment on the case, as it would break Black's privacy rights.