I think there is a significant amount of reform required for the AML regime.
It's been about 26 years since the PCMLTFA was meaningfully modernized. We haven't seen a parliamentary review for some time. I think we are slightly overdue on that.
We would like to see reform in various areas, but let's start with modernizing the legislation. We want to look at the governance of the PCMLTFA regime, and we want to look at the legislative tools that the regime has. Then we also want to look at information sharing. What's been discussed today is critical, but it's the amount of information flowing to FINTRAC that isn't necessarily leading to results.
There's a significant degree of reporting. As my colleague mentioned, there are 400 fields in Canada for an STR, versus 35 in Australia. There are a lot of ways we could pare down those fields. There are a lot of ways we could reduce the number of transactions that are reported and still yield tangible results—in fact, better results. You would create less noise in the system, and you'd be better able to use the information at hand to empower law enforcement. We want to see that sort of sector-specific supervision to ensure that areas of risk are receiving the appropriate oversight and then sharing information.
I note you mentioned Bill C-22. There are some changes in Bill C-2, which is still out there, that we would like to see from an AML perspective. Those are the public-private safe harbours. Those are the safe harbours that allow federally regulated organizations to use the information, without threat of liability, that law enforcement is providing to them, the pre-production information that allows organizations subject to the PCMLTFA to properly focus their efforts on risk.
First and foremost, I think a meaningful review of the legislation is required, but we have a lot of ideas, as I've just covered, as to the direction we could go in to really help boost results.