Finance committee  The registration scheme for MSBs, for example, will make us much more efficient, because we will be able to identify all of them and make sure they're brought under coverage. Moreover, the administrative monetary penalties will make it possible for us to be more effective in ensuring compliance.

Finance committee  Where we have a more frequent contact with them, it involves discussion about sanitized or generic issues that illustrate some difficulties arising from their having failed to recognize the value of a particular corner, or—

Finance committee  No, it isn't. When law enforcement is looking for help, they will generally provide a voluntary information report to us. If we have information we judge to be relevant—we make the determination whether it's reasonable to suspect relevance in an investigation—we are then required to make the disclosure.

Finance committee  We have begun. We've done quite a lot of work. More needs to be done, and a round of consultation with other agencies needs to occur. We will also need a round of consultation with the industry to ensure that we're getting it right. The whole purpose of proceeding down this path was that in the current regime we have the power of persuasion—and we can be quite persuasive—but there is also the power to refer for criminal investigation prosecution.

Finance committee  Not millions a day, but there are millions a year. There are about seven million a year of those transactions reported, and similarly about seven or eight million wire transfer reports of $10,000 or more. We've invested quite heavily in technology, and we've trained our analysts very extensively.

Finance committee  We deal with them directly all the time, but not on specific cases. We are prevented from discussing a case beyond simply saying, here are the transactions we have found, here are the people who are involved, and so on. The information that we're authorized to disclose, we could also say orally to them.

Finance committee  We're already at the top of the scale. We're among the top three or four organizations like ours in the world. This will move us up another notch or two, but others are also moving up. Many of the things that we're proposing to undertake in this legislation are also being undertaken by other organizations; as the international standards rise and new laundering methods are discovered, all of us are having to strengthen and expand the coverage of the legislation.

Finance committee  The short answer is no, there have not been any convictions and there have not been any allegations of improper disclosure, and to the best of our knowledge--and our knowledge is very good on this point in our organization--there has been no improper disclosure of information from FINTRAC.

Finance committee  Real estate dealers, agents, and brokers are covered by the legislation and are required to report suspicious transactions.

Finance committee  No, we are not permitted to query police. We have access to some of their databases, which record factual information--Mr. Brown has been convicted three times for X, Y, or Z--but we're not actually authorized to query the investigators as to whether they know anything more about this person or the next person.

Finance committee  Let me describe the process we go through in determining whether we will establish a memorandum of understanding for information exchange with another organization. We undertake a fair bit of due diligence. We look at questions of integrity and corruption. We look at whether the entity has the capacity to protect information physically if we provide it to them.

Finance committee  Are we talking about foreign financial intelligence units, or law enforcement?

Finance committee  That was the trade-off at the time the legislation was passed, because it was felt to be important to be able to look at large quantities of objectively reported information, in other words, large cash transactions or international wire transfers, which individually are not in and of themselves suspicious, but they are the types of transaction among which it was known that a fair amount of suspicious activity was occurring and could occur.

Finance committee  That's really not a question I'm able to answer.

Finance committee  Can you add anything to that?