Thank you, Mr. Chair, and to our witnesses for your testimony here and helping us with our report.
I'm going to start with Ms. Iafolla. Thank you very much for your presentation. You've said there are prescriptive rules that are brought out but that there is no guidance. That seems to be one of the sticking points here, so I'll give an example of a low-tech approach and then a high-tech approach and just ask you to comment.
A low-tech approach would be when you have a new teller who subjectively views someone as suspicious based on whatever criteria and makes a report to FINTRAC. From what we've heard from the perspective of Minister Eby from British Columbia, there's a warehouse where that report goes, and whether or not it goes anywhere else is up.... So there's no feedback to help the bank that may have a lower-tech approach to dealing with these things.
Then we have a high-tech approach where maybe it's a bank owned by a foreign subsidiary that's doing business lawfully in Canada and it has an algorithm that ferrets out these kinds of issues, whether it be anti-terrorism or money laundering. What ends up happening, though, because these are prescriptive rules and because they're basically forced to put it into a FINTRAC report, is that FINTRAC may not have the capacity to say “this is what our algorithm says” as the case for it.
Do we really have a mismatch with FINTRAC's one-size-fits-all approach?