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Finance committee  Yes. We work very closely with our international partners and share best practices all the time. As a matter of fact, we are looked at as one of the best financial intelligence units worldwide. Many times people come to us for best practices. Project Protect, which Mr. MacKillo

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  I don't have anything top of mind, but I do want to thank the committee. I think the work you're doing and the number of witnesses you're speaking to is very heartwarming for us. We want to hear your recommendations. We want to know what your thoughts are. As well, I believe a l

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  That's exactly what we want to work with businesses on. As you have noted, the banking sector, the major reporter sector, actually has put a lot of these systems in place. A lot of the reports we get, whether it be the large cash transactions or others, just happen automatically

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  Thanks for that. I would argue, though, that it cannot be one size fits all; there will be a different burden depending on the size and on the reporting entity. That is why it will be so critical to really work with the industry. To put in a goal before we've sat down with the in

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  First of all, I think the former director came to the committee and spoke to the decision that he exercised under his discretion. The one thing I'd probably say, though, is that under the legislation the way it currently is, a bank cannot be named until all proceedings have been

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  I heard the same thing when I met with the banking association as well as a number of banks individually. As I mentioned originally in one of the comments I made, there is a sweet spot in terms of protecting Canadians' privacy and the Charter of Rights and being able to share the

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  On the question in terms of this requiring legislation, I believe we have all the capacity to be able to do it. In terms of how we do it, whether legislation is put forward or whether we are asked to do it and we find a way to do it, there's one thing about looking at the data, b

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  I can speak and I'll let Barry jump in after. In terms of the move from an audit approach to an assessment approach, it is a move that is extremely important. As Barry mentioned, and I believe I might have mentioned, by moving to an assessment approach we're still doing a revie

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  Absolutely. That's actually a better way to put it.

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  And outcomes. It doesn't matter if we have 100 very minor deficiencies that really don't have an effect on the outcome, but I might have one deficiency that has an effect on the outcome. Therefore, I need to focus on the one that is important, not the 100 that actually I can just

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  I think it is appropriate to look at the guidance document that Finance has put out. It is appropriate to take a look at what we need to deal with new technologies, whether it be cryptocurrency or blockchain. I'm not convinced that means there is a change in legislation. I think

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  Absolutely. As I mentioned, we know what information we need, but we also need to take a look at the collectivity of information from all of our reporting entities and to ask the question: what exactly do we need from the various reporting entities and how can we actually get it

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  Yes. It's very important to provide training and educate all entities that submit reports to FINTRAC on their obligations. It's one of the things we do. After we really started doing more outreach, we noticed a big improvement in the quality and types of reports coming in. We nee

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  As I mentioned in my opening remarks, and as my experience has proven, at least at Service Canada, it is about working with the banks. It is about service. It's about smaller reporting entities. It's not just the banking sector. Burden is important to us at the centre. When you t

May 24th, 2018Committee meeting

Nada Semaan

Finance committee  I think it will be difficult to measure something that is at another location. I think we can talk about what the burden is in terms of the requirement. We can focus on measuring, but we also need to focus on addressing it in terms of finding different ways. We are talking to dif

May 24th, 2018Committee meeting

Nada Semaan