—the banks are not the major part of the problem here. Everybody fingers the banks, but as I point out in my brief, the problem is that 90% of this illicit money never flows through banks. The banks already do a pretty good job, not just because of legislation, but primarily because, on the one hand, they're afraid of fines, in particular U.S. fines, and the reputational risk associated with them. We can see this with regard to Commonwealth Bank of Australia. The banks, I think, are actually doing a reasonably good job. What the banks need is much better collaboration with FINTRAC in terms of domain awareness. Hence, I cite the Australian precedent, but there are other precedents, for instance from the U.K. and other jurisdictions, that I could cite. There are best practices that we could implement and which current legislation in Canada explicitly prevents FINTRAC from doing.
On April 18th, 2018. See this statement in context.