Finance committee  Exactly.

Finance committee  Currently, as I mentioned, if individuals are engaging in financial activity that is particularly egregious, they are generally terminated as clients. Financial institutions are still able to kind of use whatever intelligence they've garnered internally. I think that given the dearth of prosecutions that we see in Canada and the limited activity that we've seen in this area—

Finance committee  That was an excellent response. I'd just like to add that financial institutions themselves have taken up a sort of quasi-enforcement activity whereby they engage in a process known as de-marketing or de-risking. They wind up using the intelligence that's garnered through police transactions within their own institutions and then adjudicate and remove from their client roster individuals who exceed their risk tolerance based on that.

Finance committee  Yes, there should be checks and balances. I don't think that capacity should be unfettered, by any means. I think it is very important that if that capacity is provided to financial institutions, and I believe it should be, that capacity should be based on as much verifiable, substantiated information as possible.

Finance committee  Absolutely. It's a huge resource. I don't think there's anything wrong with disclosing patterns and typologies, much in the way that FINTRAC does in its current reports but in ways that actually are useful to those bodies who are responsible for generating that intelligence in the first place.

Finance committee  I think that's a fair characterization, and I also think there are problems on both sides with this low-tech, high-tech distinction you mention, and it's important to highlight them. High-tech doesn't necessarily mean objective. Individuals—you, me—could theoretically create an algorithm.

Finance committee  You're very welcome.

Finance committee  Certainly. As you know, regulations are set forth by the government. This is no surprise to you. Financial institutions are left to implement processes. Once legislation came in, they all built up their anti-money-laundering, anti-terrorist-financing units piecemeal, as things came through.

Finance committee  It could be possible that FINTRAC could provide information to financial institutions in a way that isn't necessarily put on the website for organized crime syndicates to use. It could even be to say, “We've received x number of reports from you, and we've been able to utilize and invest in x number of investigations into these reports.

Finance committee  Hello. My name is Vanessa Iafolla, and it's an honour to appear before the committee as part of the current review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Thank you so much for the opportunity to contribute today. I'll be speaking from some of my research findings.