Good afternoon. I would like to thank the Committee for the opportunity to speak to Part 4, Division 34 of Bill C-69, An Act to Implement Certain Provisions of the Budget Tabled in Parliament on April 16.

My name is Hartland Elcock, and I am a Senior Legal Counsel with the Canadian Bankers Association. I am joined by my colleague Lorraine Krugel, the CBA’s Vice President of Privacy and Data.

The CBA is the voice of more than 60 banks operating in Canada, employing more than 280,000 Canadians and helping to drive Canada’s economic growth and prosperity.

Our members take the fight against money laundering seriously. As some of the most active reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, they devote significant resources to their anti-money laundering and anti-terrorist financing (“AML/ATF”) programs, internal controls, and employee training.  Much of this investment focuses on continuous improvements to address the shifting landscape of compliance requirements and the evolving nature of money laundering and terrorist financing risks Their goal is to effectively deter, detect and report suspicious activity and to mitigate money laundering and terrorist financing risks.

As major stakeholders within the Regime, our members’ participation moves beyond simple compliance. They actively collaborate with Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) on public-private partnership (“PPP”) projects to improve the overall efficiency and effectiveness to help generate intelligence of practical value to law enforcement’s investigations. An example of the numerous PPPs in which our members participate is Project PROTECT, an innovative PPP between banks and FINTRAC to tackle illicit proceeds from human trafficking.

The CBA and its members also consistently support the Government of Canada’s efforts to enhance the Regime. For example, the CBA and its members are active participants on the national Advisory Committee on Money Laundering and Terrorist Financing. We have also been vocal advocates supporting provisions that would allow for more investigations and prosecutions of money laundering offences, including calling for a comprehensive beneficial ownership registry and increased information sharing for AML and ATF purposes.

To this end, we welcome the private-to-private information sharing framework proposed in Bill C-69. As long-time supporters of the need for improved information sharing, these changes represent a significant step forward for the Regime. We have appreciated the Government of Canada’s consultative approach to the framework’s development.

In alignment with Financial Action Task Force guidance and in agreement with British Columbia’s Cullen Commission, it is essential that public and private sector entities have the requisite authorities and protections under Canadian law to facilitate information sharing for the purpose of detecting and deterring money laundering, terrorist financing and sanctions evasion. In particular, providing a framework to improve and structure the flow of information between key private sector stakeholders will allow for more targeted disruption of illicit activities and assist law enforcement’s investigations. Ultimately, this will protect Canadians and the integrity of the financial system.  We also believe that this private-to-private sharing could increase privacy protections for Canadians by reducing unnecessary reporting to the government on low-risk transactions.

Thank you again for the opportunity to appear today before the committee, and we look forward to your questions.