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.
I concur with the points made by my colleague, Ron King, in particular with the need for policy change that would allow for greater information sharing among Canadian financial institutions, as well as between FINTRAC and reporting entities.
TD is committed to our responsibility to detect and deter money laundering and terrorist financing, and we believe that allowing for more information sharing between Canadian financial institutions would make Canada's financial system more effective by building a more comprehensive picture of a customer's activities when potential money laundering or terrorist financing is suspected. Our experience has been that other jurisdictions have considered this same issue and have created AML regimes that allow for information sharing amongst financial institutions, all the while still respecting an individual's privacy rights.
In addition we were pleased to see the economic action plan 2015 announce better access to basic banking services by allowing a broader range of personal identification to open an account. TD supports a policy framework that provides for the expanded use of customer identification techniques for both face-to-face and non-face-to-face transactions.
From an AML regime perspective, financial institutions' use of existing and emerging technologies provides them with new techniques to identify their customers, particularly those operating in an online environment. The use of pass codes, out-of-wallet-type questions, credit bureau checks, and even markers from the computing devices being used all provide valuable information when identifying a customer. They can significantly enhance customer due diligence practices, gathering numerous pieces of information in a safe and secure manner for use in customer identification. This can also assist in identifying suspicious transactions that might be related to money laundering or terrorist financing.
These policy changes would not lighten the regulatory burden or weaken the regulatory environment. They would actually enable regulators—in this case, FINTRAC and OSFI—to review and judge the practices of individual institutions and make risk-based decisions about the anti-money laundering and anti-terrorist financing program of each institution.
We look forward to seeing the details of these specific government proposals in the coming days and weeks.
In conclusion, TD believes that these changes, combined with greater information sharing among financial institutions, will significantly strengthen the Canadian regulatory regime to prevent money laundering and terrorist financing.
I look forward to today's discussion and I am pleased to answer any questions that committee members may have. Thank you.