Information & Ethics committee  On if the information had been released from within FINTRAC...?

Information & Ethics committee  We will look at basically....

Information & Ethics committee  Well, we have done some work and we'll continue to do some work to establish whether, in fact, the leak came from our organization or not.

Information & Ethics committee  We have a result of the first phase, which doesn't show anything, and then we'll go to the second phase.

Information & Ethics committee  Yes, it is us.

Information & Ethics committee  I think, Mr. Chairman, the way for us to make the public understand that we don't do this on an arbitrary basis is to explain over and again the grounds on which the decision was taken. For us, that's the best way of proceeding so that the public can see that the decision was reasonable, given the circumstances at the time.

Information & Ethics committee  The reason we signed an agreement with Manulife was to avoid a long court proceeding that might have taken years and would have meant that, at the end of the process, people might not remember why the individual was penalized. Moreover, we would have no control over what the court would decide.

Information & Ethics committee  I don't think it would be appropriate for me, Mr. Chairman, to comment on accessibility to the legal system.

Information & Ethics committee  Yes.

Information & Ethics committee  We were receiving phone calls from the media inquiring whether it was this entity, that entity, or this entity, so obviously some journalists—

Information & Ethics committee  It's difficult to assess if it is one for one. What we know for a fact—and we could provide you with numbers for it—is that we see now and have seen over the recent three to five years a significant increase in the number of the suspicious transaction reports we receive. Last year, we received 125,000 suspicious transaction reports, which are really the bloodline of what financial analysis is all about.

Information & Ethics committee  What's going to happen in the future is that we will look at the circumstances at the time. We will look at the results of the examinations, we will look at mitigation measures, we will look at how the entity behaves in terms of compliance with the regime, and we will take a decision on those grounds.

Information & Ethics committee  The entity cannot be named and the penalty cannot be imposed until the full process is exhausted, which includes court proceedings. If an entity were to decide to go to court, the case might be sealed, which means that you might never know there was a penalty, you might never know the name of the entity, and the court decision might take years before we know what it is.

Information & Ethics committee  The issue for me at the time was, do you face a potential court proceeding, which might take years before we see the results, or do you send a timely message of deterrence? Uncertainty versus certainty: I opted for the certainty at the time, and the message. Given the results we've seen with the increase in a number of transaction reports we've received, and given the conversation we're having with the financial sector, I think the message was received clearly by all entities under the regime.

Information & Ethics committee  Yes.