Finance committee  Sure. I'm happy to talk about the issue broadly. Again I'll turn to Charlene. I think Charlene listed a number of new disclosure partners for FINTRAC. The goal there is to allow FINTRAC to use its intelligence products and disseminate them to a broader set of law enforcement agencies and regulators in order to inform their review.

Finance committee  I would say they remained sort of stable.

Finance committee  We haven't been re-evaluated formally by the FATF since 2016. It can only happen every five to seven years, but there was a reassessment in 2021 and our ranking went up in some regards and down in others.

Finance committee  No. Beneficial ownership and transparency were one of the gaps listed by the FATF during the 2016 review.

Finance committee  We can take that back. I don't have the numbers.

Finance committee  Okay.

Finance committee  No. Since the last review, the government has been trying to address a number of gaps. There are some long-standing gaps, like the coverage of lawyers in Canada's regime. The Supreme Court determined that solicitor-client privilege stopped lawyers from being covered, but—

Finance committee  In March 2023, in addition to releasing the regime strategy and some of the performance metrics, we released the updated national inherent risk assessment. The national inherent risk assessment, or the NIRA, is the tool through which we work with our intelligence and enforcement partners to identify risks and how those risks are evolving.

Finance committee  On the use of cryptocurrency, again, there are benefits and disadvantages to the technologies that underlie these innovations. I think one of the drawbacks from the AML and ATF perspective is that the use of cryptocurrency often masks, from a privacy perspective, who the users are.

Finance committee  I'll speak very briefly to it, and then I'll turn to Charlene. She has more specifics on it. We've looked to expand the number of parties to which FINTRAC can provide disclosure reports. We've also looked at that in the context of sanctions and the use of potential intelligence to inform sanctions evasion and things of this sort.

Finance committee  We're looking at it in the context of money laundering and terrorist financing. Fraud would be a broader criminal issue for the undertaking as it relates to RBC.

Finance committee  I understood that. The undertaking relates to RBC given that they're the party undertaking the transaction. They are required to apply enhanced due diligence and ensure that they're meeting all the objectives. To the extent that the minister would find that they are not doing that, it would be at the minister's discretion to determine whether she wanted to take measures as a result of that.

Finance committee  Because HSBC is exiting the market, the obligation falls onto RBC as the entity that now owns HSBC.

Finance committee  Do you mean in terms of their previous compliance with the AML and ATF?

Finance committee  I can't say whether that was a consideration, but no, the undertakings relate to RBC to ensure that on a going forward basis, it is compliant.