Finance committee  Yes, I would be happy to. First, I think this committee is aware that banks provide millions of reports to FINTRAC every year. We're excited by seeing a provision that would have more output from all that input. I think what this provision is trying to address is the mens rea o

Finance committee  Thank you for the opportunity to speak with the committee today as part of your study of Bill C-97, specifically on the changes in division 2, part 4 of the legislation, which deal with anti-money laundering and anti-terrorist financing. My name is Sandy Stephens and I'm an assi

Finance committee  I would add that what I think we're advocating for with the technology is a technology-neutral approach to legislation. Right now it's a three-year credit bureau...or photo ID. You don't need to have prescriptive legislative requirements. You could have a principles-based flexibi

Finance committee  The banks have put a lot of resources into this, and we're not suggesting that we don't want to keep that level of resource. We just want to get the most output for that resource, and we feel the best way to do that is to focus on the highest risk customers or typologies. Somet

Finance committee  I'll start, and then I'll let my colleague add. We're moving to a digital environment. That is the way of the world. Innovation is being fostered at all levels, including the government level, and a lot of those transactions or account openings are moving into the digital sphere

Finance committee  I think this is an incremental change. There's already a provision in PIPEDA under paragraph 7(3)(d.2) that allows for sharing for preventative purposes for fraud. It states specifically that it's where it's likely to be committed. It's not a wholesale sharing of information. It'

Finance committee  Exactly. It would just be adding in another element. It's not just fraud but predicate offences to money laundering, as well as money-laundering offences.

Finance committee  FINTRAC is given information. It currently doesn't have the ability to provide information back down to private industry. There is sharing at the governmental level, obviously, but there's no ability to share back down.

Finance committee  No, but that is also one of our recommendations: that they have the ability to come back. Again, that would allow for more targeting, so you're not boiling the ocean so much with all of this reporting. With information sharing, etc., you can have a more targeted approach.

Finance committee  Thank you very much. The Canadian Bankers Association would like to thank members of the committee for inviting us to participate in the review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. On behalf of our member banks, we welcome the opportunity to c

Finance committee  “Adviser” is a term that is used in securities regulation for a defined set of functions, but an “advisor” is a more generic term. The reality is that people are regulated based on their functions and activities. If they're doing certain functions that fall within the “adviser” c

Finance committee  Within a bank there's a myriad of ways for an employee to escalate a concern. They can go to their direct manager, they can go to HR, but they also have an internal ombudsman system which is independent, and someone can look at their complaint. Also, we're a federally regulated i

Finance committee  Could I just follow on with that? At a bank, there are multiple controls that relate to performance management. The code is one, but there are a number of controls: training, coaching, etc. So, that's just one control.

Foreign Affairs committee  A consolidated list for smaller institutions would be very helpful, absolutely. Just from an efficiency perspective, why not do it once, as opposed to, as you said, hundreds of times?

Foreign Affairs committee  I think we mentioned a hotline or a telephone line for advice as well. The banking industry is appreciative of all the support the government has provided us. We're just looking for enhancements in that collaboration.