Finance committee  I would just like to add that FATF, the Financial Action Task Force, also does a major evaluation of Canada, and part of that major evaluation is also looking at FINTRAC as a financial intelligence unit. They recently changed their methodology to include an effectiveness component to the way they assess different countries' regimes.

Finance committee  Agreed.

Finance committee  Thank you, Mr. Chair.

Finance committee  On a tactical level, Mr. Chair, they're actually forbidden under the law to be provide us details on the information we've provided them.

Finance committee  That's right.

Finance committee  FINTRAC has in the past provided feedback to TD at, I would say, a very macro level as to the data quality of our reporting. But, no, we do not currently receive regular updates from FINTRAC or feedback on our reports, nor do we receive more tactical information back on the reports we've submitted to FINTRAC.

Finance committee  I think it's important to remember that part of why the banks exist is the trust that our customers put in us to protect their information and their assets, and the privacy related to that. So we have a vested interest that anything we want to do in trying to combat money laundering or terrorist financing that allows for greater information sharing of a customer's personal information be done within the proper framework to keep that information secure.

Finance committee  In TD's experience because of our North American presence, we have a fair number of branches located in the U.S. The U.S. has a regime there under the Patriot Act, section 314(b), that allows for this type of information sharing among financial institutions. It's under the auspices of their equivalent of FINTRAC—FinCEN.

Finance committee  I'll maybe answer more from a TD perspective. To my earlier opening comments about the responsibility to detect and deter, having a lot of these procedures and processes in place has a deterrent effect of keeping the bad guys out of our financial system. We also then do further monitoring and risk assessment of the ones who are in the system, to identify them to FINTRAC and hopefully get them out of our system and dealt with by law enforcement, To the extent that brings a compliance burden on us as a bank, we do look for opportunities to make sure that what is coming to us from the government, from a regulatory or guidance perspective, works in practical terms with how banking works.

Finance committee  Between federal agencies there is a lot of work happening in that regard, and I understand there is regulation to allow for that to happen. What we're interested in, as we are a key partner in the regime providing that information to FINTRAC and then further on to law enforcement, is whether there is an opportunity there for us to be part of that as well, bringing in the private sector in that greater information sharing.

Finance committee  Yes. Maybe I'll start with the hypothetical where we see unusual or suspicious activity happening in a bank account. That information may involve money coming in from other institutions within Canada or being sent out. It may actually be transactions that are happening among a number of different subsidiaries within, say, the TD Bank Group or any of the big banks' affiliates.

Finance committee  No. That's one area that we're proposing should be looked at, to allow for that to happen. Right now, because of the way the privacy legislation is constructed, and the fact that the current AML legislation is silent on this fact, we aren't allowed to be able to provide each other with that type of information.

Finance committee  I would agree with what Mr. King said. It's important to keep in mind as we think about how criminals continue to evolve in their methods and techniques that to do this they will look for the path of least resistance to be able to facilitate their means, be it from a money laundering or a terrorist financing perspective.

Finance committee  I think a challenge that we are facing collectively right now, as a partner in the regime, is emerging technology and different ways to transact in a mobile environment. We have to keep pace with that in the way we construct our policies and procedures to onboard or monitor clients.

Finance committee  Thank you. Good morning, Mr. Chair, and members of the committee. Thank you for the opportunity to appear before you here today on this very important topic. For the past four years I have been the deputy global AML officer for the TD Bank Group. Prior to joining TD, I worked at FINTRAC for approximately 10 years.