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Finance committee  Thank you, Mr. Chairman. It is a sincere pleasure to appear before this committee as you begin your review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. I'll also refer to it by its better-known acronym of PCMLTFA, or more simply, the act. My intentio

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  Thank you for this question. It really goes to the heart of the questions that confront the regime. We currently do strike a balance between privacy, burden, and results. I would like to emphasize the considerable effectiveness of the current regime in deterring criminal and te

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  That's another excellent question. The international attention to money laundering and terrorist financing is active, robust, thoughtful, and it brings a high standard of excellence to these questions. The advice that we received from the FATF is geared towards exactly those obj

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  I agree on many elements of what you put forward. The real-estate sector is a clear area of concern within the regime, although we currently have in place a series of requirements on the real-estate sector. I would point in the first instance to FINTRAC's efforts to raise compli

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  We also read the attorney general's speech closely and are quite concerned about the number of challenges that he has set forth. FINTRAC has been working closely with the casino sector and, in particular, in British Columbia to trace through the charges that have been put on what

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  I would say that the sector has been consistently marked as an area of concern and there are efforts to make sure that it's fully compliant with the requirements of the regime, and that appropriate efforts are put in place to follow up on the issue.

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  The short answer is absolutely. That speaks to the integration across international efforts to make sure that we have consistent systems, and we put a lot of attention on those types of transactions, both through the formal sector of financial institutions and through the sector

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  Thank you for the question. To give you as accurate an answer as possible, I am going to switch to English. I would point to a summary in the discussion paper, which describes recent efforts to evolve the regime. A number of those legislative and regulatory changes responded to

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  Thank you for the question. The short answer is yes. We consider the inability to find out who is behind a corporation as one of the more significant priority areas for action in the Canadian landscape in respect of money laundering, terrorist financing, and tax evasion. This

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  That's another excellent question. The issue of administrative and monetary penalties is under active discussion, especially at FINTRAC, but also with other partners. At its core is a tension between discretion versus rules essentially. The issue is whether FINTRAC can achieve

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  The issues with real estate and the various themes that you put forward are really at the crux of some of the more difficult and important issues that we hope to move forward with in this review and subsequent legislative changes. If I may say, the issues that you spoke to inclu

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  The issue of beneficial ownership is an important one. To reiterate, we think that the point of having corporations in the first instance keep basic records in a standardized way that can be used by law enforcement entities or be provided to financial institutions as current requ

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  In the first instance, the efforts are focused on beneficial ownership of a corporation. We have different thresholds and concepts at play in different federal and provincial statutes right now. At the federal level, under the PCMLTFA, the level of control is 25%. That differs by

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  Ian is closer to this one. I'll turn to him.

February 8th, 2018Committee meeting

Annette Ryan

Finance committee  Mr. Chair, I have one specific point, which is that we've done an operational review of our effectiveness as a regime, and we see a need to address the standard of prosecution in this space. Right now, we require the standard of proof to tie the money launderer to the discreet

February 8th, 2018Committee meeting

Annette Ryan