Thank you very much, Mr. Chair.
You're right. In May 2016, the Federal Court of Appeal in the matters of Kabul Farms and Max Realty agreed with the FINTRAC assessment that these entities violated the PCMLTFA. The court recognized FINTRAC's authority and its assessment that violations had occurred.
The court also ruled, essentially, that the information that was provided to the penalized entities about the penalty amount was insufficient. The court really ruled on that matter, and not on the substance of the FINTRAC authority to issue a penalty.
We are now reviewing every unique factor that could be detrimental to the penalty amount based on the harm done. Those are all criteria that are currently in the legislation.
We're committed to being completely transparent about that new method. We want the reporting entities to be very well informed and understand in plain language the consequences of violations under the PCMLTFA.
It's important for the committee to understand that we do not penalize for money laundering. This is not the role of FINTRAC. We penalize for violations to the PCMLTFA, which are administrative violations.
There are approximately 200 violations possible under the act, so that's what we look at. That's what we have to assess, and we have to determine what harm is done to the regime when they violate the—