I will start at the beginning of the process. We start with a risk-based assessment of entities, trying to identify which ones may be susceptible to not complying with their obligation to report—not to money laundering, but to their obligation to report. Once we've done that process we conduct an examination. The examination reveals a certain number of things. If the entity does not agree with the results of the examination, they have the right to ask for a review, which is conducted by a separate side of FINTRAC. The review unit makes recommendations to the director as to whether the penalties the examiners would propose should stand, based on a series of criteria, or attached to the violations themselves. For instance, some of them may be attached to the capacity of the entity to pay.
Then, depending on my response, whether I want to stand with the suggestion or change the decision taken by the examiner, then entities have the right, if they want, to go to court.