Yes, sir. Again, this has been provided to the committee in a brief, so you should be able to review it there as well.
Currently, there's a proposal in the legislation to have a criminal offence for failing to provide FINTRAC with information or for providing incorrect information to FINTRAC. We don't have a problem per se with the offence, but as with many fraudulent statement offences under the Criminal Code, there's an intent to deceive.
What we wouldn't want here is an unintended consequence where someone in good faith has, through an examination process, let's say, with FINTRAC, decided to provide certain information in response to FINTRAC. Perhaps the information, in their view, was correct or perhaps they failed to provide information because it simply wasn't needed, based on their good-faith judgment. We wouldn't want a criminal censure to be placed against a good-faith action by a compliance officer in an organization. The unintended consequence is that you can impact both the hiring and retention of high-quality staff in this important area in the bank.