Finance committee  We will analyze them. We must by law analyze them. We must review them. If we have some transactions that relate to this and we actually reach a threshold, we must disclose them.

Finance committee  Our focus is first on money laundering.

Finance committee  No, we would have to analyze it first.

Finance committee  I don't have a sense of that for one good reason. The legislation has just recently changed, so as a result, all the cases that we referred to the CRA were first money laundering cases involving potentially drugs or fraud, etc., and tax evasion. Because the legislation has now made tax evasion a predicate offence, and there are regulatory changes as well--sorry, that was a regulatory change.

Finance committee  In the vast majority of cases, there would have been a referral to the CRA as a result of also making a referral to a police force, because we had determined that it would also be relevant to a tax evasion offence, if you wish. So it would have been primarily as a result of the referral to police.

Finance committee  The cases we refer to the CRA are money laundering cases, which are essentially what we would be referring. Obviously, with the component for reasonable grounds to suspect tax evasion, it's difficult. As you said, we're only ramping up. I would suspect there will be a significant increase given that we have seven or eight additional analysts.

Finance committee  We can receive volunteer information from the public. As long as the information is related to a money laundering offence, we will analyze the information. We will make a determination on whether or not, first of all, we have any information in our database related to that and whether or not, after the analysis, if we reach that level of the legal threshold, we will disclose it to the police or to the CRA, depending on the situation.

Finance committee  I'm not sure about the wording you've used in respect of “when in doubt”. When we have reasonable grounds to suspect that it's money laundering, and also reasonable grounds to suspect that it's related to an offence of tax evasion, then I would refer it. I must refer it.

Finance committee  Yes, there is a double threshold for money laundering: you must have reasonable grounds to suspect money laundering and reasonable grounds to suspect tax evasion--

Finance committee  Because the legislation requires me to reach that threshold.

Finance committee  We can't be in doubt. I must make that determination. It's either that I suspect or not. And when we reach that threshold, we must disclose.

Finance committee  No, if you transfer that internally or offshore, if it's suspicious, they will report that to me as well.

Finance committee  Yes. I gave you a very simple example, because we were referring to indicators, and I didn't want to make it too complex. I didn't really come here prepared with charts. But most of the cases are fairly complex. With respect to very complex situations, where you may have comingling of funds or large corporations perhaps using offshore locations, because some of those sites might raise a red flag, among many others, yes, there are cases.

Finance committee  Chances are that this particular amount would not be reported to us unless the bank thought it was suspicious. I'll give an example of a cash deposit of more than $10,000. If an individual transferred that amount outside the country, I would be getting an EFT, an electronic fund transfer, from that bank.

Finance committee  First of all, if the $1 million is suspicious, they would send it to me, so I would get that. If the $1 million is deposited in cash, I would get that.