That's another excellent question.
The issue of administrative and monetary penalties is under active discussion, especially at FINTRAC, but also with other partners. At its core is a tension between discretion versus rules essentially.
The issue is whether FINTRAC can achieve better success by working with entities towards compliance and the right point at which to apply administrative penalties and with what amount in the appropriate channels with due process followed. These are what I would describe as the key elements in that discussion.
We are seized with getting the balance right, and getting a regime in place that will hit that right balance between effectiveness and transparency and compliance.