I know there's a bit of a rabbit hole when we talk about these issues, but again, if someone owns an asset and then issues a lease that is not registered anywhere to someone else, and that someone else is operating that asset in a way that is used to launder money, we're not going to know about that, because there is no formal registry.
I do understand that we are in a world where we are coming to terms with many of these arrangements, that things like beneficial ownership and significant control are relatively scattered terms, and that trying to bring some consistency with international standards is difficult. I do think that it might be one area, perhaps, that the government may be wanting to investigate because, again, if you make a change, then organized crime will make changes to their behaviours to structure their affairs in a way that is compliant but allows them to continue their opportunities.
I'd like to to switch gears. In your consultation paper, you stated that the FATF report “notes that making the penalties for violating these [anti-money laundering] laws more proportionate and dissuasive would assist in the deterrence of money laundering and terrorist financing”. What stronger penalties do you think would be appropriate in this regard?