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Industry committee  That question is better directed to officials at Innovation, Science and Economic Development Canada. I can tell you, however, that more and more countries are considering a public registry model, even if it goes further than the international standard. As previously stated, the bill provides a balance between the publication of information and the protection of information that will be disclosed to government authorities, including exemptions.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I would mostly echo. It's one of our largest legislative gaps in terms of anti-money laundering. If this legislation doesn't go forward, we wouldn't be plugging that gap federally. It would most likely impede our progress to implementing a pan-Canadian solution, and we would continue to be offside our international standards, our international obligations.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I'm not certain all the provinces and territories have that threshold. It may be nine out of the 10 provinces.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I can't give you any details. I know that the government signed an agreement with the provinces and territories in 2017, and it was further to those discussions that the 25% threshold was established. That's where the threshold in Bill C-42 came from.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I don’t know. We’re in a state of uncertainty. We’ve been talking about a certain threshold with the provinces and territories for about six years, and we have a plan of engagement to find a pan-Canadian solution to this. We believe that all provinces and territories can adopt the approach proposed in this bill.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  The primary goal of the federal approach is to ensure interoperability with the provinces and territories. It is designed with that goal in mind. There are, however, many technical details that will need to be discussed with the provinces and territories. The portal, for example, comes to mind.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I can’t really comment on the size of fines in other countries.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  Standards exist to help countries understand what the main risks are and what main actions they should be taking to address those risks. They are standards. They're not prescriptive, in general, so each country can implement them in its own way. There are technical standards, which refer more to legislation and regulations, and then the FATF assesses effectiveness.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I don't have an estimate on the workload. I would echo comments by Mr. Beaudoin. From a strictly anti-money laundering perspective, more information is better. However, in terms of providing advice on anti-money laundering policy, we always look to the administrative burden and whether something is “implementable”, if that's a word.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  Yes. There's always a cost-benefit of collecting more information versus the potential burden put on reporting entities in our case and on corporations in the case of this bill.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I would say that money laundering is something that all jurisdictions in the world struggle with in terms of addressing. In terms of successes, perhaps my colleagues can give specific examples. What does good look like? The standards are set by the Financial Action Task Force.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I'm beginning to regret giving that statistic, which was provided by the United Nations. I do not own that statistic. I'm just trying to be helpful and provide information. That's not just in Canada. That was a global range—2% to 5%. I spoke already about the limits of the methodology.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I'm sorry. I'd have to look back at specifically what that office does in the Canadian context.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  I'm not sure those were my words, to be honest.

June 12th, 2023Committee meeting

Justin Brown

Industry committee  Without commenting on whether or not this bill is perfect.... As I said, if it were passed, based on international standards and our own examination, it would leave an important gap for corporate beneficial ownership registries on a Canadian approach. It would cover up to 15% of incorporations in Canada that are done at a federal level, which, obviously, leaves up to 85% or more at a provincial and territorial level.

June 12th, 2023Committee meeting

Justin Brown