The committee was studying Bill C-12, an act respecting certain measures relating to the security of Canada's borders and the integrity of the Canadian immigration system, and heard from Hartland Elcock and Michael Donovan of the Canadian Bankers Association, Chief Superintendent Pat Morris of the Ontario Provincial Police, and Assistant Commissioner Derek Santosuosso of the Royal Canadian Mounted Police.
Hartland Elcock, representing the Canadian Bankers Association, said the bill's focus on supervision and compliance is welcome but proposed several technical amendments to ensure transparency and predictability, including deferring increased administrative monetary penalties until regulatory criteria are set, adding a regulation-making power to define what makes a compliance program reasonably designed and effective, removing the one-year limit on extending compliance remediation agreements, relying solely on reporting entities' judgment to determine if a client's name is obviously fictitious, exempting banks from mandatory FINTRAC enrolment due to existing oversight, amending the false information offence to require intent to deceive, and clarifying that offences alleged before the bill's coming into force are not subject to new provisions. He argued these changes would prevent over-reporting and help FINTRAC receive actionable intelligence, and noted that banks already invest heavily in compliance and participate in public-private partnerships like Project Guardian.
Michael Donovan, chair of the CBA's anti-money laundering specialist group, echoed Elcock's support for the technical amendments, stating they would help ensure a risk-based regime that keeps pace with evolving threats. He added that the bill's provisions on supervision and identification of individuals involved in the AML regime, combined with appropriate penalties for non-compliance, should help strengthen the regime against typologies like the Vancouver model of money laundering, and pointed to the government's national risk assessment as a guide to vulnerabilities.
Chief Superintendent Pat Morris of the Ontario Provincial Police said Bill C-12 will enable operational effectiveness through improved border security authority, intelligence sharing, financial intelligence integration, and enhancements to the Controlled Drugs and Substances Act, but stressed that the most critical missing element is lawful access to modern communications, including on-device investigative techniques, which he argued is not a new power but a restoration of capacity lost as criminals moved to encrypted platforms. He said this is essential to move beyond opportunistic interdiction to proactive intelligence-led operations against transnational organized crime, and noted that the OPP works collaboratively with the RCMP and other services through joint technical assistance centres.
Assistant Commissioner Derek Santosuosso of the RCMP focused on the bill's amendments to the Sex Offender Information Registration Act, which he said would allow the RCMP to share information on registered sex offenders with domestic and international partners when there are reasonable grounds to believe it will assist in verifying compliance, executing warrants, or preventing or investigating a crime of a sexual nature, including with Passport Canada. He also welcomed amendments to the Controlled Drugs and Substances Act that would exempt RCMP members from criminal liability for drug-related inchoate offences when conducting lawful investigations, and said the RCMP supports both Bill C-12 and Bill C-2, noting that Canada is the only Five Eyes country without lawful access legislation.
During the meeting, a member raised concerns about the lack of interpretation services and the absence of the Canadian Bankers Association's brief in both official languages, which the chair acknowledged.
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