Thank you very much for the invitation to share a few additional comments, and I do have some.
I'll start with the fact that the FATF, the Financial Action Task Force, in its report about Canada noted that some of the penalties for violating their AML or ATF laws are not proportionate and are not dissuasive. It recommended that they be changed, which I wholeheartedly agree with.
It also seems to be symptomatic of a larger problem within a number of Canadian laws when it comes to both the enforcement and the penalties. I remember testifying before a committee a few years ago on Canada's export and import compliance issues. There was a case in April 2014 of a company called Lee Specialties Ltd. of Alberta that was fined for the unlawful export of some dual-use goods to Iran. They were charged $90,000, but the company had a revenue of $29 million so it was a very small penalty. This spoke to—and a number of international experts spoke to—Canada's poor rate of prosecution and low penalties for some of these compliance issues.
Another recommendation I had pertained what a previous witness, Mr. Shahin Mirkhan, said. He said, “I'm sure you will direct FINTRAC to check out the Iranian government officials who have dual citizenship in Canada. They are achieving money laundering to Canada from Dubai, Europe, and everywhere else.” That was what he said. He's actually quite correct that Iranian government officials and their family members are using Canada to invest money that has been illegally obtained, particularly through corruption. Iran has one of the most corrupt governments. This is not a point for contention; I can provide endless evidence to that point.
I felt that in respect of this, besides using FINTRAC and our law enforcement agencies to better investigate this type of issue, we should also be using our other existing and complementary laws more effectively. I know that Canada recently passed its own Magnitsky law, as did a number of other countries. I know we imposed sanctions on some Russian officials and some Venezuelan officials, but we haven't imposed any sanctions on Iranian officials under the Magnitsky law. What Magnitsky was created for is exactly what these guys are doing. It has to do with gross human rights abuses. It has to do with profound and systemic corruption. I would just argue that as we study our regime here, we should also focus on the other laws that we already have in Canada and on using them more effectively.