Finance committee  I think the industry would be looking to the government to provide parameters that would define in which circumstances and precisely what type of information could be exchanged, and requirements as well for the participants in those information-sharing activities to be legally bo

Finance committee  So a separate body to oversee the activities of FINTRAC?

Finance committee  As I've said before, these risks of money laundering and terrorist financing are evolving continually. As opposed to necessarily an oversight body, I believe the regime is subject to periodic parliamentary review, and I think as part of that review we should have a comprehensive,

Finance committee  Thank you, Monsieur Côté. I think we do apply a risk-based approach today in Canada. In fact, the guidance from FINTRAC—and FINTRAC is working on additional guidance now on the risk-based approach—and the guidance for Canadian federally regulated financial institutions from the

Finance committee  Certainly for financial institutions it would remove a burden that today is fairly onerous in respect of reporting of transactions at the $10,000 threshold. Not only must we report transactions individually that meet the $10,000 threshold, but we must aggregate multiple transacti

Finance committee  They're not mutually exclusive because these two typologies share a number of things in common. Very often they're the same vulnerabilities within the financial sector and other regulated entities that the criminal element will seek to exploit. As I mentioned earlier, things like

Finance committee  Obviously, there are existing safeguards behind the walls of FINTRAC that prevent and limit how they disclose information when it comes to them. Our role in the financial sector is providing the information to FINTRAC so that they can convert it into intelligence. I think what we

Finance committee  Thank you, Mr. Labelle. It is difficult, and very often where thresholds are set for the reporting of information, one of the first things the criminal element does, whether money launderers or terrorist financiers, is to find ways of avoiding those thresholds. The other thing

Finance committee  The constituents in the regime need to work closely together.

Finance committee  I agree with those comments. I would just add that this is a relatively immature business, this whole thing of anti-money laundering and anti-terrorist finance, with most of the progress being achieved in the last decade or so. I think some of our learnings have been that it very

Finance committee  If I may, there are two points I'd like to make. One is that all of these alternative technologies very often ultimately need to find a link into the legitimate or the traditional financial system in some way, shape, or form. In some respects, if you can put in place safeguards

Finance committee  In answer to your second question first, I think the answer is yes. And one of the things that we've observed is that to the extent that we've been successful in our attempts to limit money laundering and terrorist financing, it's an amorphous type of threat and it will change ve

Finance committee  The primary activities we have in respect of terrorist financing are twofold. One is screening of names. There are names published by the United Nations, Canada, and other countries that are on the terrorist lists. We screen our client lists globally against those names on the te

Finance committee  Terrorist financing, as I said in my earlier remarks, is difficult to identify, because often it's about the intent of the use of the money. We've seen some innovative typologies where they've actually employed criminal activities, including credit card fraud, the trans-shipment

Finance committee  We get general guidance, but we don't get any specific feedback with respect to any of the specific reports we submit.