Good afternoon and thank you for inviting the Canadian Bankers Association to appear today to participate in the Committee’s study of the invocation of the Emergencies Act and related measures. My name is Angelina Mason and I am General Counsel and Vice President of the CBA.

The CBA is the voice of more than 60 domestic and foreign banks that help drive Canada’s economic growth and prosperity. The CBA advocates for public policies that contribute to a sound, thriving banking system to ensure Canadians can succeed in their financial goals.

On February 14, 2022, the Government of Canada invoked the Emergencies Act and made associated Emergency Measures Regulations (Regulations) and an Emergency Economic Measures Order (Order). All financial service providers, including banks, covered by the Order became legally obligated to implement the measures as stipulated by the Government in the Order.

Banks took great care to fully understand their obligations and to ensure that they limited the Order’s application to activities that fell squarely within their intended scope. The Government indicated that the measures were intended to be temporary and focused only on a narrow group of individuals and entities involved in specific activities covered by the Order. The vast majority of customers were not impacted by these measures.

Upon receipt of information from the RCMP regarding individuals and entities engaged in conduct or activities prohibited under the Regulations, banks acted in accordance with their legal requirements under the Order. We can confirm that banks acted quickly to unfreeze accounts after the RCMP notified financial service providers that it believed that individuals and entities previously identified were no longer engaged in conduct or activities prohibited under the Regulations.

While most of these accounts have been unfrozen, it is important to remember that some of these accounts may still be frozen to comply with court orders or proceedings not related to the invocation of the Emergencies Act.

On February 23, 2022, the Government revoked the Regulations and Order and the associated legal obligations of banks and other financial service providers ceased.

The Public Order Emergency Commission contacted the CBA during the investigation phase of its work. To support the Commission in its mandate, the CBA provided an overview of how the banking industry responded to the Emergency Economic Measures Order, and the role that the CBA played in this process. The CBA cooperated fully with Commission Counsel including participating in a formal interview, providing an institutional report, and producing requested documentation. We anticipate relevant information will be shared by Commission Counsel as part of the overview reports to be introduced during the public hearing.

Thank you for your time and I look forward to your questions.