Information & Ethics committee  Yes. However, as I was saying, we ourselves need to establish that the threshold has been reached before the information is shared.

Information & Ethics committee  The Privacy Commissioner basically conducts an assessment of our privacy framework every second year. So far he has conducted two audits, and he is in the process, in fact, of finalizing his third one. On every occasion his conclusion has been that we never disclose information f

Information & Ethics committee  Thank you, Mr. Chair, for inviting us to speak with you regarding our handling of an access to information request in relation to the penalty that FINTRAC levied against a Canadian bank in 2015. As Mr. Chair just mentioned, I am joined today by Barry MacKillop, our deputy direc

Information & Ethics committee  We need to look at each case. It's very difficult to generalize the approach that should be taken. In 2013 the policy was changed because I thought that naming organizations that we penalize for smaller amounts of money gave them a bad name and did not necessarily change their b

Information & Ethics committee  I will start at the beginning of the process. We start with a risk-based assessment of entities, trying to identify which ones may be susceptible to not complying with their obligation to report—not to money laundering, but to their obligation to report. Once we've done that proc

Information & Ethics committee  Yes.

Information & Ethics committee  Yes.

Information & Ethics committee  Yes.

Information & Ethics committee  The entity cannot be named and the penalty cannot be imposed until the full process is exhausted, which includes court proceedings. If an entity were to decide to go to court, the case might be sealed, which means that you might never know there was a penalty, you might never kno

Information & Ethics committee  The issue for me at the time was, do you face a potential court proceeding, which might take years before we see the results, or do you send a timely message of deterrence? Uncertainty versus certainty: I opted for the certainty at the time, and the message. Given the results we'

Information & Ethics committee  Yes.

Information & Ethics committee  It's difficult to assess if it is one for one. What we know for a fact—and we could provide you with numbers for it—is that we see now and have seen over the recent three to five years a significant increase in the number of the suspicious transaction reports we receive. Last y

Information & Ethics committee  What's going to happen in the future is that we will look at the circumstances at the time. We will look at the results of the examinations, we will look at mitigation measures, we will look at how the entity behaves in terms of compliance with the regime, and we will take a deci

Information & Ethics committee  We were receiving phone calls from the media inquiring whether it was this entity, that entity, or this entity, so obviously some journalists—

Information & Ethics committee  They were just asking, “Is it this one, this one, or this one?” So, obviously somebody either had guessed or got information from somewhere as to who the penalized entity was. Despite the fact that it was out there, and despite the fact that we had a confidential agreement with M