Finance committee  Good morning. My name is Carmina Hughes. I'm very pleased to be here today representing the TD Bank Group. At TD, I am the global anti-money laundering officer or, as we call it, the GAMLO. I am responsible for AML compliance in all the jurisdictions in which TD operates. I hav

Finance committee  Multilateral.

Finance committee  At TD we follow the same courses you've heard of from the other banks. We have a global standard. We have to assure ourselves that we have reasonable proof as to who we are dealing with in terms of our customers. Of course, in different jurisdictions there are different peculiari

Finance committee  Actually, I'm not sure how extensively the Canadian government is involved in leading the charge, but certainly it's a well-respected member of the G-20 along with a number of other international initiatives. When I was at the Federal Reserve Board, for instance, Canada took the

Finance committee  I think you've already heard that one of the things we all do, and we have an obligation to do, is to know our customers from the front end. We determine what we expect to be the baseline type of activity as well as the purpose of the account. We look into other aspects of the cu

Finance committee  For what purpose would we identify the customer?

Finance committee  If it's a high-risk individual, we have centralized enhanced due diligence groups in Canada and in the United States, as well as in other locations, such as the U.K. We try as best we can to have a global view of our customers, but it's not always possible, for reasons that have

Finance committee  Yes, in whatever country. Is there anything else that I missed?

Finance committee  We do a number of things upon someone's application in order to determine whether they are worthy of being hired at TD Bank, whether in the U.S. or in Canada. One of the things we do for all employees is to run through the sanctions lists with them. There are multiple lists here

Finance committee  I think they're very similar, actually. There are some nuances, certainly, that are different. In Canada there are more prescriptive requirements in terms of opening accounts than there are in the U.S. I think it's an often misunderstood notion that the U.S. is more regulated tha

Finance committee  I'll be very brief. I think what I say will be universally held by others. From a bank's perspective, of course we have an obligation to our shareholders to operate in a responsible manner and to return to them as best a return on their investments as we can. As a corollary to

Finance committee  Well, I think it's a business strategy. You have to look at where you are and how you intend to grow your business. For us, to go into risky areas is not part of our strategy. Our risk appetite is fairly conservative. I think that has served us well over the last so many years. A

Finance committee  As does TD.

Finance committee  Yes, in that we file suspicious transaction reports if within the course of the payment we discover there is a financial institution involved in the payment that we think may have done something wrong.

Finance committee  Yes, we have enterprise standards in that regard.