Finance committee  A number of things would impact that small law firm. The first, and I think the most important, from that example is that law societies on their own have imposed a cash prohibition rule on lawyers so that they cannot accept large amounts of cash. They can't accept more than $7,500 in respect of any single transaction.

Finance committee  Yes, she has been consulted. There have been a number of meetings with the Office of the Privacy Commissioner, but I would let her speak for herself.

Finance committee  At a very high level, those are the key components.

Finance committee  I'm not sure what your reference is to four changes.

Finance committee  I think what the honourable member was referring to is the fact that the Proceeds of Crime (Money Laundering) Act was, post-September 11, 2001, amended by the Anti-terrorism Act to add a terrorist financing mandate to FINTRAC's existing money laundering mandate. The Anti-terrorism Act amended the proceeds of crime legislation and renamed it the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

Finance committee  Yes, it was budgeted for. The funds required to implement these initiatives were allocated in budget 2006. That's the $64.4 million over two years that was referred to.

Finance committee  It's not.

Finance committee  We have maintained that we believe there are already very strong privacy concerns in the legislation.

Finance committee  We have not made any changes in respect to the privacy side.

Finance committee  No, it's not.

Finance committee  FINTRAC is already subject to extensive oversight and reporting requirements. It tables an annual report in Parliament, as you know. It submits a departmental performance report annually, a report on planning and priorities. It's subject to the privacy legislation. It has to report on its compliance with the Privacy Act and the Access to Information Act.

Finance committee  I can't answer that question. That's a question for the Senate.

Finance committee  What Ms. Ablonczy has already mentioned is that in order to share information with its partners, FINTRAC must enter into a memorandum of understanding that must be approved by the Minister of Finance. One of the key pieces of the memorandum of understanding is to ensure that there are adequate privacy protection provisions that we are comfortable with in the handling of that information if and when it is shared.

Finance committee  If you're asking me if it's actually specifically in the bill, what I'm saying is that there's a memorandum of understanding that must be approved by the minister, and it makes the privacy protection provisions a key component so that the information cannot be shared.

Finance committee  I don't want to prejudge the outcome of the Financial Action Task Force evaluation, so that's a tough question for me. There are challenges that are unique for Canada among its FATF partners. We have much stricter privacy laws in Canada, for example. And the charter sometimes imposes some challenges on us.