There can be cases where penalties are warranted. We don't have a specific example where we would say that you should adjust it one way or the other, but I think it's important to recall the objective of this legislation, which is to detect and deter money laundering. The reporting entities, such as brokers and salespeople, are not the ultimate target. The money launderers are the ultimate target. The discussion on the compliance burden or whether the penalties placed on them are enough sometimes distracts from the real issue, which is what we can do to encourage more suspicious transaction reports being made to give FINTRAC what it wants.
On March 27th, 2018. See this statement in context.