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An extra segment of debate in the @HoCChamber occurred for Bill #C42 tonight and here's a short thread with my reaction: #cdnpoli #endsnowwashing
Man, we succeeded in branding. Almost every elected official who spoke referred to Canada's AML regime weakness as snow-washing. There was also recognition that 45bn to 113 bn annually is being laundered into #Canada. Our work was heavily referenced by all parties.
On 25% vs 10%: This is better suited for study during the PCMLTFA hearings this summer. Yes, it could be possible to reduce the threshold in the bill, yet there would be a lot of pushback from Canada's business community and by FINTRAC reporting entities. Not worth it.
On real estate: This is where provinces need to step up and create BO property registries such as the BC LOTR. There are constitutional barriers to adding RE to Bill #C42. It would require significant legal study and would likely be challenged in court. Not worth it, either.
On interoperability w/provinces: The first part is legislatively designing the registry to be interoperable with provinces, which #C42 does. And, the second is ensuring the architecture can be interoperable, which is a work in progress.
On the 1st part, the Government has committed to using #BODS which will help registries "speak" to one another. Next, is ensuring provinces and territories have a flexible agreement structure w/feds to opt-in, or design their own registry that is harmonized with fed parameters.
On the 2nd part, the feds need to develop reliable front/back-end systems which are robust enough to hold BO information w/out any weaknesses. This will be a test for government IT projects in general, and all eyes will be watching #Canada to ensure this project is successful.
On penalties: We were happy to see increased penalties for serious offenders up to 100K for corporations and 1 million for UBOs. Sophisticated criminals would not have been deterred by previous penalties which were much smaller, and easy to absorb as a cost of doing business.
On crypto, UWOs, and ML typologies: Important to remember that a BO registry is one tool is aimed to tackle illicit flows of $ through companies or properties and is not a panacea for AML. The arguments in the @HoCChamber need to be addressed when #Canada reviews its AML regime.
Summary: Proceed one step at a time, and don't let perfect be the enemy of the good. Bill #C42 is a good step and the complementary pieces can be addressed in parallel and in the future. Trying to jam all AML deficiencies into one bill will run into eventual challenges. #cdnpoli
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