Finance committee  I would reiterate that we see millions of Canadians owning cryptocurrency now, mostly because they're interested in this technology, the asset class and the promise that it holds. We see great companies being built that have cryptocurrency as part of their core corporate strategy.

Finance committee  I think the FINTRAC record is to be reviewed, but I think there are hundreds of companies that are licensed and registered for virtual currency money services in Canada. There's a huge range with everything from those ATMs you might see in a corner store to digital platforms like Newton or Wealthsimple, to companies based entirely outside of Canada that have taken a step at licensing in Canada.

Finance committee  I'll take the first crack at it. I think it's a good question. One thing I would say is that with respect to cryptocurrency businesses based in Canada, like Newton, Wealthsimple and Ether Capital, a court order or a legal development can be put in place directly, to which actors based here must be responsive.

Finance committee  Sure. I think it's helpful to distinguish the freezing of accounts from the blocking of money movement and crypto movement to fund the activities. We did find it generally more straightforward to identify Bitcoin addresses that were associated with fundraisers and to block transactions to those addresses.

Finance committee  That's right.

Finance committee  Sure. I will probably defer here to both Brian and Dustin, who I think have more technical expertise than I do. My personal view is that there's not that much of a difference from a platform like ours. It's just like how someone might decide to use their credit card to process transactions on a GoFundMe or GiveSendGo platform.

Finance committee  Sure—

Finance committee  I would say two things. One, no cryptocurrency was frozen. We did, however, respond to the lists of Bitcoin addresses that had been associated with fundraisers and did block some transactions that were directed to go to those addresses. The actual quantum of amounts blocked I don't have.

Finance committee  It would be a fair comment from our perspective. Within our client base, we did not see any significant volume of attempts to fund a transaction for the convoy.

Finance committee  I think the initial order and the breadth of that definition you've alluded to did present challenges for companies like Wealthsimple. We have a very highly skilled team of AML professionals and lawyers and are fortunate to work with many very experienced colleagues, but all of us were working very hard and calling everyone we knew—peers in the industry—to try to understand how people were interpreting and applying those definitions, both to be able to be responsive to government policy and the law and to also not cast too wide a net.

Finance committee  In my view, I'm not sure that retroactive guidance would be particularly helpful at this time. I think we're learning a lot. We'll look forward to the reports of this committee and the other federal study of the Emergencies Act. Going forward, though, if we were ever in the position where we needed to invoke an emergency act in the future, I think that having more preparation around how we communicate between industry and government and law enforcement—perhaps running tabletop exercises so that the RCMP actually has contact information for every financial firm subject to the AML laws in order to be able to communicate directly—would put us in a better place if we were ever in a similar position again.

Finance committee  I think that's right. We have obligations under anti-money laundering laws to follow a risk-based approach to screening clients and transactions on our platforms, so every regulated intermediary will make appropriate decisions on how to interpret and apply that risk-based approach.

Finance committee  We did not. We were sort of on the receiving end via notices received through indirect channels and through publication of orders on government websites. I think it's an area for improvement. On a theme of engagement, which has been mentioned here today, it would have been helpful to have had more direct communication with the Department of Finance.

Finance committee  Sure. We received several notices from the RCMP. Those notices came to us via industry associations, regulators and law firms. The notices were helpful in that the original emergency order was extraordinarily broad. It was a concept of designated persons, which was very difficult to interpret.

Finance committee  I'll go first here. There are two phases to this inquiry, Adam. The first phase was during the blockade when the Emergencies Act and the emergency order were in effect. During that time period, we were screening our client lists against the names provided by the RCMP to identify any connections to our client base.