I'm no longer part of the legal team, but I think there are two different things you're talking about. One is our requirement and our obligation to comply with the law. You're all aware that sanctions are criminal statutes, so you do have to have a positive match. We have very specific requirements under the law to block and freeze and report.
We do everything in our power to make sure we identify the right entity or individual if we're ever going to do that. We make sure we have an exact match, and that's why I made the point earlier that it is very rare in Canada that it happens, from an account holder or even a securities transfer perspective.
What might be more common is that we see on the other side of a wire transaction that the recipient of funds may be a listed person. That's more common. It's either that, or the recipient looks likely to be listed—for example, there's an exact name match, but we don't have any other information.
Our process is to hold until we verify. Almost every international bank we deal with takes the same approach. You interrupt the transaction on the basis of information that leads you to believe that it is, in fact, a listed person because the name is either close enough or exact. Then you pursue additional avenues to clear that. It's based on information you can obtain on that transaction.