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TI Canada Makes Submission to House Standing Committee on Finance on PCMLTFA

Transparency International Canada followed up on its testimony to the House of Commons Standing Committee on Finance, by providing formal submissions on the government’s review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act to Hon. Wayne Easter, Chair, Standing Committee on Finance, and to Ms. Lisa Pezzack, Director General, Financial Systems Division, Financial Sector Policy Branch, at the Department of Finance.

The submission focused on the following topics:

  • Canada’s AML/ATF regime must be more comprehensive, coordinated and transparent

  • Reduce legislative and regulatory gaps

  • Bring the legal profession into the AML/ATF regime

  • Expanding the scope of the PCMLTFA to High Risk Areas

  • Enhancing the Exchange of Information and Transparency

  • Strengthening Intelligence Capacity and Enforcement

  • Modernizing the Framework and its Supervision

You may read the full submission below.

TI Canada recognizes the important work of all the anti-money laundering and anti-terrorist financing regime partners, including the critical work of reporting entities. We stress, however, that Canada needs to do much more not only to keep up with international standards that were set in 2012 by the Financial Action Task Force (FATF) and meet the G20 commitments on beneficial ownership, but also to implement the forward-looking best practices of like-minded jurisdictions, such as the United Kingdom and the European Union.

We believe that Canada’s reputation as a “snow washing” jurisdiction and as the location of the “Vancouver Model” for laundering money is symptomatic of our governments’ (federal, provincial and territorial) lack of resolve and leadership to fundamentally address the problem of money laundering and terrorist financing (ML/TF), corruption, tax evasion and other financial crimes. Canada’s track record since being a founding member of the FATF has shown it to be reactive and prodded into action only in times of crises or international criticism, resulting in the perception of being a laggard in addressing ML/TF.

It is our hope that the recommendations that we put forward will be accepted and implemented before the next legislatively mandated review of the PCMLTFA.