Thank you very much, Madam Chair.
Thank you to the witnesses.
I'm going to direct my questions to Professor Turnbull.
Although there has been a lot of focus as of late on Beijing's election interference in the 2019 and 2021 elections, during the 2015 election there was also foreign interference and foreign money that was directed to third party organizations that were registered.
For example, in 2017, I wrote to the commissioner of Elections Canada with a complaint in which I had identified that a total of $693,023.50 had been transferred from the Tides Foundation, which is based in California, to eight different third party groups: The Council of Canadians, the Dogwood Initiative, Ecology Ottawa, Équiterre, Greenpeace Canada, Toronto350, the West Coast Environmental Law Association and the West Coast Environmental Law Research Foundation. None of that was reported by any of those eight third party groups. They did spend a total of $317,426.80 in the 2015 election.
In short, when Elections Canada responded, they said effectively that there was nothing they could do because of certain loopholes that existed in the legislation at that time. The government did move forward to amend the Canada Elections Act, with really significant amendments in Bill C-76. I know that you appeared—I think at this committee—on Bill C-76.
The Chief Electoral Officer, in his report on the 43rd and 44th elections, does in a section speak about some of the issues around third parties, in which he notes that some of these loopholes still exist—at least two.
One is that there's a melding issue. That was an issue with respect to my 2017 complaint, in which funds donated to a third party, even from a foreign source, can be treated as melded and as part of the general revenue of the third party. A second loophole is that a third party can accept contributions from another entity and report having received those funds from that entity, even though those funds may have come from another source.
That's a long preamble, but I think it's important to provide some context in terms of loopholes or gaps that exist within the Canada Elections Act.
I know that you have studied the act and you've appeared as a witness. Do you have any recommendations on how we can strengthen the Canada Elections Act to stop the flow of foreign money?