Thank you for the question.
With the money-laundering piece, certainly when we look at other jurisdictions, Canada is behind with respect to combatting money laundering and terrorist financing. Other case studies are already in play in Europe, Estonia, Netherlands and the U.K. There is also information sharing in the U.S. This allows those organizations to uncover networks of criminal organizations that are leveraging the fact that individual organizations in Canada have to report to the government, but they cannot follow up to see whether or not the transactions will go to another organization. That other organization may not be reporting to the government, so the government cannot see the whole piece of the puzzle with respect to those criminal networks.
This information sharing will allow for more targeted and effective reporting. We believe that it will actually increase the privacy of Canadians. Right now, when we look at the amount of reporting that goes from organizations to the government on a per capita basis, it's twelve and a half times more than in the U.S. and 96 times more than in the U.K.
The approach we're proposing is narrower than what the GDPR permits. Many organizations can leverage the legitimate interest provision in Europe to be able to do this type of sharing. Because the legitimate interest in the CPPA does not permit disclosures, we're proposing that it be linked to the proceeds of crime act to really limit that sharing.