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Finance committee  That's correct, which is why I say we primarily relied upon them. They were coming to us with a rather limited but definitive list.

March 7th, 2022Committee meeting

Angelina Mason

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  No, I would say there was a balance. There were a number of individuals.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  That would not even hit the radar. that's why it wouldn't happen. If anyone has any question, they should contact their bank. That's not what would have happened. It would have been for something else. It would have been that, perhaps, they had gone over a certain limit, but it would not be because of the Emergencies Act.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  I do not have that information.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  There aren't, to my knowledge. I could take that away. As part of our advocacy within the AML space, we have supported the expansion of reporting entities to address gaps, including cryptocurrency, which was recently included, so I can take that away to see if there are any additional ones that we, as an industry, have supported.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  With a court order, we are legally obligated to do it. The benefit of the court order is we're not asked to validate anything.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  We were given names and asked to validate against them. It isn't your typical process. I agree with you. In the case of sanctions, there are prescribed lists that have already been reviewed.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  Sure. In the case of sanctions, we're very familiar with and have a long history of implementing economic sanctions within Canada. It's a known process, so when individuals and entities are named and particular actions are restricted, we've been able to implement those in the past.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  I'm sorry. It's not a court process. I believe when the sanctions are invoked, it is a government process.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  Not necessarily. Orders may not provide it at all. First of all, in some cases, orders may not specifically address notice. In other cases, orders are required to be kept confidential. It really does depend on the specific order.

March 7th, 2022Committee meeting

Angelina Mason

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  I would say that the guidance being provided by the government was well within the specific language in the order itself. Obviously, all of our banks have in-house counsel. I myself am counsel. We all would have looked at the order itself and seen what the scope of those obligations was.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  That is correct.

March 7th, 2022Committee meeting

Angelina Mason

Finance committee  A suspicious transaction is one that, based on the facts, suggests that money laundering might be occurring.

March 7th, 2022Committee meeting

Angelina Mason