Foreign Affairs committee  Sure.

Foreign Affairs committee  It's a valid point and a good question. The larger financial banks in Canada use service providers, quite frankly, to help us with list generation. Some of us use the same service providers. There are a number of them out there that are best in class. We don't really share info

Foreign Affairs committee  If you're re-engineering the administration of sanctions, I would encourage the committee and the government to look at a number of jurisdictions and pick and choose elements that are the best from each, but you have to think about what works for Canada. I picked Australia becau

Foreign Affairs committee  I'm no longer part of the legal team, but I think there are two different things you're talking about. One is our requirement and our obligation to comply with the law. You're all aware that sanctions are criminal statutes, so you do have to have a positive match. We have very sp

Foreign Affairs committee  Yes, but I want to distinguish between a listed person and sanctions—

Foreign Affairs committee  —from a suspicious AML activity. That's a very different threshold. If the police are investigating in a potential crime, they will need a court order, typically, to interrupt a payment. It varies. If we suspect it may be money laundering, that's a whole other issue.

Foreign Affairs committee  The advantage of sanctions is it's a bit more black and white. If you're dealing with a listed person, the obligations under the law are very clear. You have to block. You freeze and then you report, so we do that.

Foreign Affairs committee  Just off the top of my head, I know that there are at least.... We're talking about not just lists but sources that you would find on various websites. It may not be actually 19 under the legislation or the regulations; I think it's just that the locations at which you would ac

Foreign Affairs committee  There are two things. One is that from a list perspective and for list administration, we're asking just to put it in one spot, as OFAC does. There would just be one list. It doesn't matter whether it comes from different pieces of legislation. Have one central list, and then you

Foreign Affairs committee  Yes, that would be very helpful. Let's take Russia for that example. There are subtle differences among the U.K., the U.S., Australia, and Canada, but if those regimes could just agree on uniformity of language and approach, it would be ideal.

Foreign Affairs committee  That's for a permit application.

Foreign Affairs committee  Correct. Our lawyer follows up, and asks what's happening with it. The response is just that it's still in process.

Foreign Affairs committee  Yes.

Foreign Affairs committee  That would be helpful.

Foreign Affairs committee  Absolutely. Yes, it would definitely be beneficial, and it's something we've been asking for over a number of years. Your esteemed committee member mentioned the credit unions and the small financial institutions, and we believe for them especially it's a burden. For smaller bank