Chairman Rajotte and distinguished members, thank you very much for this kind invitation.
I want to also thank you for allowing me to submit a fairly lengthy document. I obviously won't go through it, as we'd be here all morning, but I do want to cover some highlights, if you will permit me. I want to talk from an operational perspective on what I'm seeing. Having been in law enforcement for 34 years now, as well as more than seven years in compliance, I think I come with a unique perspective, seeing both sides of the world.
I think we have to accept that terrorists consider themselves at war, one with no rules or uniforms. Terrorists camouflage themselves in our civilian population in order to unleash their fury upon unsuspecting targets and symbolic structures. The reality is that they're out there, and I think we have to accept that. With Canada's recent expansion into Syria, I would suggest it also means that we have to be more alert than we were in previous times.
The reality is that for financial institutions, identifying suspicious activity, especially for terrorist financing, is extremely challenging. I would argue that there has to be a more concerted effort in a public and private partnership, where there's collaboration between law enforcement and the financial institutions. I know that some of this is sensitive information, but I firmly believe we can appoint somebody with security clearance to be a chief anti-money-laundering officer in a bank. We can have them appointed as a point of contact in, for instance, emerging situations.
I can give you an example. I just came back from the financial crime conference in New York. One of the bank chief anti-money-laundering officers spoke of being contacted by the FBI at three o'clock in the morning on a very serious matter. Because of the relationship that had been established, she went to the bank that had been previously arranged and was able to pull off the data about the financial flows, which were extremely valuable in the investigation. When we're dealing with terrorist situations, we're dealing with real time, and I believe that's something that's essential.
I think one thing we need to do is to be more efficient and effective in assisting financial institutions. The other thing I think we need to do a better job of is providing financial institutions with the typologies that FINTRAC is seeing so that the financial institutions can better serve the overall goal of what we're all trying to stop—terrorist financing and the financing of organized crime.
The other aspect I'd like to talk about is that when we put up sanctions against Syria, they were very laudable sanctions. I think we'd all agree with them. But what happened as a result is that all of the money services businesses that had Syrian clients were shut down by the banking community. The problem for us, and it is a problem, is that all of that money continued to flow in an underground economy. Neither law enforcement nor the intelligence agencies.... I can tell you that I have submitted a number of intelligence briefs on this, because I have a number of contacts in the Iranian community, and none of those have yet to be followed up on. I still get examples of where in the newspaper they're still advertising for their services.
This concerns me greatly, because this has been going on for a period of about four years. How much of that is related to terrorist financing? I suggest that if we're going to allow foreign students to come from Syria, we also have to accept that they have to have some vehicle to flow their money. I would suggest to this committee that the fact that we allow the MSBs and that they are monitored with independent reviews—the one that I was doing I was monitoring quarterly—is of value, because we know exactly what's going on and who the people are. I suggest that's far better than an underground economy.
The other area I'd like to speak to is the fact that this whole area requires expertise. I can tell you that I was very fortunate; I guess I was an anomaly in the RCMP, because I started in the proceeds of crime and money laundering area in 1983, at the embryonic stage, under the auspices of Rod Stamler. I helped developed the program. I can tell you that over the years, frustration crept in. I ended up leading the program at the end, and I watched expertise constantly going out the door because of our antiquated belief that we have to have a rank-based system. That is an 18th century philosophy when we're fighting 21st century crime. We have to get to the point where skill is an absolute requirement. We need to build up that expertise. I can tell you that when I left the RCMP, my average experience was 1.7 years.