Information & Ethics committee  I think the entities are doing much better than they were doing before, yes.

Information & Ethics committee  We can look at the kind of deficiencies and the number of reports we see now that we didn't see before. With the interface we have with them from an interrelationship standpoint, their commitment and engagement is very different today from what we had in 2008.

Information & Ethics committee  Well, as I've said before, Mr. Chair, we're in a conversation with the Department of Finance as to what pieces of the compliance program and the penalty program need to be reviewed. What would it mean to name at the beginning of the process? We need to assess that from a legal standpoint, as well.

Information & Ethics committee  Well, I don't know specifically. Paul may know specifically which information you're referring to. The issue we had with this case was very different from the issues we face normally. Normally, of course, we redact according to the legislation. In this case, there were several factors that explain why it took so long.

Information & Ethics committee  Mr. Chair, I'm very sorry. I just hate the last line, “who this is”. We have no proof as we speak that the leak comes from FINTRAC. I would like that fact to be very clear. There is no proof, and I don't like insinuations that there may be. If we find who it is, there are measures in our legislation, and we will follow those measures.

Information & Ethics committee  This may stay within FINTRAC, because we have an internal process. People have obligations under our legislation and our code of conduct. Depending upon what we find, and the conditions under which the information was leaked, if it was leaked, then we'll decide what the next steps are.

Information & Ethics committee  This has never happened before as far as I know.

Information & Ethics committee  Since I've joined FINTRAC, it's never happened.

Information & Ethics committee  For almost five years.

Information & Ethics committee  Barry may provide more detail, but there were basically four things. The first is that given the size of the organization and the maturity of Manulife, we had expected that their compliance framework would be more robust than it was, in terms of policies, training, procedures, reviews of their risk profile more often by senior officials.

Information & Ethics committee  Well, they had already put in place, between the time we conducted the examinations and the time we penalized them—because we have to analyze the results of the examination—a number of mitigation measures to make sure it would not happen again. Will it happen again? The next examination will reveal that, or not.

Information & Ethics committee  Yes. The fact that they did not...warranted the million dollars that they had to pay as a penalty.

Information & Ethics committee  Yes.

Information & Ethics committee  No, we're talking about a number of people who have been working on this file.

Information & Ethics committee  It's people who conducted the investigations, people who reviewed the case, people who reviewed the appeal, the lawyers, me, and senior staff—