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Finance committee  I would say, just recognizing the limits of my own expertise, that I am here as an expert on financial sector policy, not broader criminal law. I will provide a broad response, since it would be at the discretion of FINTRAC to indicate to law enforcement where it thinks there is

June 1st, 2021Committee meeting

Justin Brown

Finance committee  I apologize, but I'm not immediately sure of the report of the audit to which you're referring. I know, for example, that FINTRAC gets assessed by the Office of the Privacy Commissioner every few years.

June 1st, 2021Committee meeting

Justin Brown

Finance committee  FINTRAC would take into account the recommendations of that audit and implement changes to bring its practices into compliance. I've had various conversations with FINTRAC. The protection of privacy is fundamental. Also, respecting charter rights is absolutely fundamental to this

June 1st, 2021Committee meeting

Justin Brown

Finance committee  I think the two of us are done. Thank you.

June 1st, 2021Committee meeting

Justin Brown

Finance committee  That's correct.

June 1st, 2021Committee meeting

Justin Brown

Finance committee  I would concur that I don't think any of the officials here tonight are able to opine on the broader policy question. I would note, and, Gabriel, please correct me if I have missed something here, but the offences listed here and where those proposed changes relate to contraventi

June 1st, 2021Committee meeting

Justin Brown

Finance committee  That goes beyond my ability to testify. I apologize.

June 1st, 2021Committee meeting

Justin Brown

Finance committee  It would depend on the investigation and what charges were brought against whom, which would lie with law enforcement and the public prosecutions group within Canada. The law, as it's written—and it's not being proposed to be changed—is “every person or entity”. The scope could c

June 1st, 2021Committee meeting

Justin Brown

Finance committee  I'm fine to answer the question. Credit unions are reporting entities under the act, so they would be subject to this cost recovery model once it is in force.

June 1st, 2021Committee meeting

Justin Brown

Finance committee  The compliance costs that have been mentioned relate to the costs the individual entities incur to implement and to be compliant with this act and the anti-money-laundering rules. This law proposes that reporting entities would become responsible for paying for FINTRAC's compli

June 1st, 2021Committee meeting

Justin Brown

Finance committee  It's still me, Chair. By way of introduction, the next few clauses, 172 to 176, relate to strengthening penalties under the act and other changes for consistent language. There are different offences listed for contraventions of different sections under this act. The changes to

June 1st, 2021Committee meeting

Justin Brown

Finance committee  Sure. The details of this specific model would be largely prescribed in regulations, so I can't say what the exact details of this would be. FINTRAC, in undertaking its responsibilities to ensure compliance with Canada's anti-money-laundering and anti-terrorist-financing rules, u

June 1st, 2021Committee meeting

Justin Brown

Finance committee  That's correct. The specific model has not yet been determined. I would just reinforce that we will consult with all of the reporting entities in advance of proposing a specific set of regulations. While I can't speak to where that discussion will land—that ultimately will be a

June 1st, 2021Committee meeting

Justin Brown

Finance committee  I think on anything blockchain- or virtual assets-related, I would bring in Gabriel Ngo, who has worked extensively on these questions. Gabe, are you able to respond to that question?

June 1st, 2021Committee meeting

Justin Brown

Finance committee  Thank you. I would just remind you that these clauses deal with the government's work to continually strengthen and modernize its anti-money-laundering and anti-terrorist-financing regime. At the previous testimony we spoke to earlier clauses that would implement a cost recover

June 1st, 2021Committee meeting

Justin Brown