In that respect, the main challenge is figuring out what types of financial vehicles are being used.

If you go through the conventional banking system, transactions will go through the U.S., simply because those international transactions are in dollars and go through the corresponding banks, in the U.S. or in Canada. The main challenge is to monitor those financial flows in the banks and in other institutions of the financial and economic sector, in order to filter those transactions and trace their profile.

Once again, there is a major problem not only in terms of money laundering—which is already complicated—and terrorist financing, but there could also be transactions that are completely innocuous. The challenge is with small funds, small amounts where the money is earned legally and sent to such and such an organization that may not even be aware that the money would then be used by an organization considered as terrorist by some states.

Furthermore, the broader issue that you raise goes beyond the financial system and banking system and deals with the potential use of other routes—or simply suitcases full of cash. Once again, the challenge is different. Basically, the system in place in Canada is a financial flow oversight system going through the conventional banking system. That has been the focus of the work.

In my presentation, I have listed all sorts of challenges in terms of detection, which is extremely difficult to do, as well as the possible misunderstanding between the two. Bankers and others will first try to protect themselves from regulators. They will show that their hands are clean and say that they have reported what had to be reported. How useful will that be afterwards for financial intelligence services? That is the question.

If I had one recommendation to make, it would be for you to reflect on that. In addition to the use of this concept of risk, whose definition seems obvious, we need to ask how each player in the process interprets risk management, how they see it and what type of surveillance and reporting that entails. Reflecting on this cooperation and on how everyone sees their role could be a very Canadian issue.

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