As part of the process, we conducted KYC due diligence activities on all the individuals prior to the CIB reaching financial close on the loan. Our KYC review would include situations where principals previously held public office. It's important to note that FINTRAC guidance talks about the act of holding public office. It doesn't impute a political definition to that act.
If we have a counterparty identified as having held public office previously, we review when that was. In most cases, FINTRAC provides guidelines. You usually do a look-back period of five years. With respect to these individuals, in several cases, the public office held was more than five years prior. That's a factor we assess as part of a risk assessment when determining whether enhanced diligence or review needs to be done on counterparties.