Isabelle Jacques

Isabelle Jacques spoke 178 times across 1 day of testimony.

  1. Isabelle Jacques, ADM (GC-FIN)

    I swear.


  2. Isabelle Jacques, ADM (GC-FIN)

    The Bible.


  3. Isabelle Jacques, ADM (GC-FIN)

    Isabelle Jacques, I-S-A-B-E-L-L-E J-A-C-Q-U-E-S.


  4. Isabelle Jacques, ADM (GC-FIN)



  5. Isabelle Jacques, ADM (GC-FIN)

    Yes. I'm Isabelle Jacques. I'm the Assistant Deputy Minister responsible for the financial sector policy. We're responsible for the development of policy in the financial sector, as I mentioned. In my team, I have five directorate, five divisions. Two of them were involved in the work that we did for the Economic Order. The first one was the Financial Crime and Security Division. The second one was the Financial Institution Division. So we are involved in a number of policy work. And in this case, we worked on both the Proceeds of Crime (Money Laundering and Terrorist Financing Act and also did work with respect to potential amendments to the Bank Act that made their way into the Emergency Order.


  6. Isabelle Jacques, ADM (GC-FIN)

    That is accurate.


  7. Isabelle Jacques, ADM (GC-FIN)



  8. Isabelle Jacques, ADM (GC-FIN)

    Yes. Proceeds of Crime (Money Laundering) and Terrorist Financing Act.


  9. Isabelle Jacques, ADM (GC-FIN)



  10. Isabelle Jacques, ADM (GC-FIN)

    That is correct.


  11. Isabelle Jacques, ADM (GC-FIN)

    That's fair. They had to review their business relationship to see whether any of the funds were used in a manner that was concerning.


  12. Isabelle Jacques, ADM (GC-FIN)

    And in these options, of course, under the Bank Act, these would not apply to, you know, provinces nor territories.


  13. Isabelle Jacques, ADM (GC-FIN)



  14. Isabelle Jacques, ADM (GC-FIN)

    But at the time, certainly when we're looking at these options, you know, the situation was evolving. So we started from a situation when we're monitoring these activities where the, you know, the -- there seems to be peaceful manifestation ongoing, and certainly the situation degenerated. So when we started looking at this we were looking at options under the Bank Act.


  15. Isabelle Jacques, ADM (GC-FIN)

    Yes, it was. So, basically, under the Emergencies Act, certainly, financial institution had an obligation to review on an ongoing basis their relationship with their clients to ensure that they were not using property to further the illegal activities that were ongoing. And certainly, in doing so, if they found out that they did have any of these property that they would have to suspend the services they provide and they need to freeze those accounts.


  16. Isabelle Jacques, ADM (GC-FIN)

    So and in trying to come to the knowledge and conclusion as to whether you had business relationship of such nature, they could do two things. The first, they could on their own, on an ongoing basis using their algorithm or processes that they have, identify suspicious transactions, or, as we allowed in the -- as we specified in the legislation, obtain information from enforcement officers, could be from federal or provincial. So we provided for information to be shared by the, you know, federal or provincial or territorial governments with the financial institution to help. What occurred in the end was that the RCMP shared information with the financial institutions, financial service providers, to help them identify those people and to vet the information they received.


  17. Isabelle Jacques, ADM (GC-FIN)

    And vet the information they received. So the obligation was on the financial institution to determine, in the end, whether or not they were going to freeze bank accounts.


  18. Isabelle Jacques, ADM (GC-FIN)

    Yes, I would say so. I mean, if you received information from the RCMP, the financial institution, financial payments service providers would have to review the information they receive and ensure that the people that are named are actually the people that are -- have accounts with that financial institution, so that's number one. Certainly, they had to, you know, ensure they had the right people, but also, on their own, as I mentioned before, they could review the information they have, use the systems they have, their algorithm to detect suspicious transaction, which they did. And on their own, they did freeze bank accounts without information received from the RCMP.


  19. Isabelle Jacques, ADM (GC-FIN)

    What I mean by vetting is being -- they -- if you read the language of the legislation, the financial service providers are responsible for taking the action, ultimately. It's their responsibility under the Act. So, certainly, they received information from the RCMP with respect to persons, entities involved in illegal activities. They looked at the information. They had to certainly confirm. I don't know what their internal process were, but I certainly know that they -- you know, from -- they reviewed the information to ensure that the people that, you know, with whom they had business dealings with people that were signalled or identified by the RCMP. But I'm sure that the financial service providers could tell you exactly how they went about that.


  20. Isabelle Jacques, ADM (GC-FIN)

    Sorry, the file is with respect to?


  21. Isabelle Jacques, ADM (GC-FIN)

    The Regulations or the Order?


  22. Isabelle Jacques, ADM (GC-FIN)

    The Regulations or the Order?


  23. Isabelle Jacques, ADM (GC-FIN)

    Yes, and that's what I mean by vetting.


  24. Isabelle Jacques, ADM (GC-FIN)

    Yes, it was our Emergencies Measure Order, yes.


  25. Isabelle Jacques, ADM (GC-FIN)

    We did not take part in drafting the Regulations.


  26. Isabelle Jacques, ADM (GC-FIN)

    It was -- the policy was developed by the Department of Finance by my branch and the drafting was done by the Department of Justice, yes.


  27. Isabelle Jacques, ADM (GC-FIN)

    Well, you have to go back in time certainly. When we were working and that there was a decision to -- we found out that there's a possibility that the Emergency Act would be enacted, we started looking at policies and options as to how we could implement and take action fairly rapidly. So we did, obviously, develop the policy that would enable for a number of, you know, federal, provincial players, like the -- in the enforcement, the RCMP could share information with the financial service providers, so that was something that was important, to help financial service providers to identify people that could be involved in illegal activities. So that was number one. And number two, we were thinking that -- knowing that on their own they could also detect fraudulent activity or suspicious activity, that they could do that as well. But as far as sharing the information, the Department of Finance does not receive information from the RCMP. That was solely between the RCMP and the financial service providers. And it was up to the financial service providers to make the determination as to whether or not to freeze bank accounts, based on the information they had. So it could be their own information, or a mixture of information received using their own, you know, risk based analysis to make a determination as to whether they would freeze.


  28. Isabelle Jacques, ADM (GC-FIN)

    Well, what I certainly heard is that they heavily relied on it, but that they did, you know, some analysis to ensure that the people that were on the list were banking in their institutions and that knowing that they were involved in illegal activities and that they had accounts, they made a decision to freeze.


  29. Isabelle Jacques, ADM (GC-FIN)

    But it's certainly based on -- heavily I know that they relied on the information provided by the RCMP. That is accurate.


  30. Isabelle Jacques, ADM (GC-FIN)

    Well, in the end, the decision -- maybe not call it exercise of discretion, the decision was -- lied, in accordance with the Emergency Order, lied with the financial institution to make the final decision - --


  31. Isabelle Jacques, ADM (GC-FIN)

    I do not know. You would have to talk to the financial service providers to see what procedure they put in place. Once they receive -- you know, we were not party to that. So I know that the RCMP did provide information. I do not know the nature and the extent of the information. And how did the bank go about freezing the accounts after that, what analysis did they do and how they went ahead, I'm not privy to the details of that operational -- those are operational steps.


  32. Isabelle Jacques, ADM (GC-FIN)

    No. No, I do not. I've never seen that form.


  33. Isabelle Jacques, ADM (GC-FIN)

    I've never seen the form. We were not privy to any exchange of information.


  34. Isabelle Jacques, ADM (GC-FIN)

    Well, if I was -- well, as I mentioned before, I’ve never seen this form, but if, you know, I put my shoes -- myself in the shoes of a financial service provider, seeing this form and saying -- basically, it’s saying that this is information about a person involved in illegal activities, and they’re providing that information to the financial service provider. I mean, that is information on which I would rely. And as it says here, it says that the entities have a duty to determine, as defined in section 3, so I’d have to refresh my memory and look to section 3, but I presume that, you know, once -- yeah, the section 3 says: “...the entities must determine on a continuing basis whether they are in possession or control of property that is owned, held or controlled by, or on behalf, of a designated person.” So if the RCMP comes to them to say this is the information about a designated person, financial institution is reviewing, in an ongoing basis, their relationship, they would, and this is a client of theirs, I would think that, you know, they will do -- as I said, they will do their vetting; “Is this one of my client? I’m informed by the RCMP, yeah, this form that the person is engaged in these illegal activities.” I would rely on that, personally. So if the financial institution did, I wouldn’t be surprised.


  35. Isabelle Jacques, ADM (GC-FIN)

    But I can’t -- again, I’m making a lot of presumptions.


  36. Isabelle Jacques, ADM (GC-FIN)

    We’re seeing ---


  37. Isabelle Jacques, ADM (GC-FIN)

    Yes, I know that.


  38. Isabelle Jacques, ADM (GC-FIN)

    But, I mean, to answer your questions, I have to make a lot of suppositions, but I take it for granted that...


  39. Isabelle Jacques, ADM (GC-FIN)

    I do not know that, but that would seem reasonable to me.


  40. Isabelle Jacques, ADM (GC-FIN)

    We certainly designed the measures and the -- with respect to the implementation, we once, you know, had discussions with various departments as we -- you have to understand that this moved very, very quickly. We went from a situation where we’re looking at potential policy options under the Bank Act, to very rapidly looking at the possibility of implementing the Emergencies -- you know, the Emergencies Act, and developing these Orders. In developing those Orders, we tried to be as practical and targeted as possible. And that’s why we wanted to ensure that information could be shared with various enforcement forces, including the RCMP. We had discussions with the RCMP and with the financial institution to ensure that we basically implemented or helped, to the extent possible, provide the information with respect to the Emergencies Act and these Orders. These are not the type of Orders -- I mean, it was the first time, I think, in 35 years, or if ever, that the Emergencies Act was ever used. We’re working on very tight timelines, and the implementation was quite rapid. We’re also working with evolving facts. We didn’t know what we were looking at. You know, the situation was evolving, there were various information circulating. And when you’re trying -- anybody that has tried to develop policies, even in normal circumstances, and to ensure that these policies are properly reflected into law and to apply that law. I mean, if -- just even that is not a simple factor. So I think to the extent that we develop the Emergency -- the Order, and that we had a successful implementation of that Order, in my view, was quite a feat. Because we focus on the people that were -- the focus was on the people that were involved in illegal activities, and that were, you know, funding those illegal activities. We also told people ahead of time that if they continue to fund illegal activities, or be involved in those illegal activities, that the bank accounts could be frozen. People had notice ahead of time, and if a decision was made to stay on the premises, to continue to stay involved in those activities, these people knew what could happen.


  41. Isabelle Jacques, ADM (GC-FIN)

    Yes, I do.


  42. Isabelle Jacques, ADM (GC-FIN)



  43. Isabelle Jacques, ADM (GC-FIN)

    Yeah, we set ---


  44. Isabelle Jacques, ADM (GC-FIN)

    Yes, as a deterrent, ---


  45. Isabelle Jacques, ADM (GC-FIN)

    --- on your second point. Yes.


  46. Isabelle Jacques, ADM (GC-FIN)

    Well I’m nodding. I mean, I just understand what you’re saying. The question ---


  47. Isabelle Jacques, ADM (GC-FIN)

    Well that’s not accurate. We were not, definitely -- the intent was not to get at the family or to have any, you know, of those impacts. That was not the focus. The focus was to be able to act quickly and it had two prongs. Like, we’re thinking, you know, we wanted to stop the flow of funds to fund those illegal activities and we wanted it to act as a deterrent. So for those people on the Hill or in other border crossings involved in illegal activities, we wanted to dissuade them from continuing their participation. As we said repeatedly, what was important was that one of the key features was we wanted to act quickly, as we said before. So as quickly as we could freeze -- the accounts could be frozen, they could be unfrozen as well. And the person that made a decision to stay involved in those criminal activities or illegal activities, it was their decision to stay there. Certainly are we conscious of the fact that we do not want, of course, you know, we did have questions and we had discussions with the CBA with respect to, you know, court order, like, for child support for example. We certainly said, as you saw in the Emergency Order, there is a section that basically indemnifies people from, you know, implementing -- doing their best to use their judgement to implement the order and the measures that are there. Certainly we said the goal was not to punish or prevent, you know, payments of child support. That was not the goal. The goal was to ensure that people who were involved would make a decision to leave. Those funds would have been unfrozen if they had, you know, made that decision, very quickly.


  48. Isabelle Jacques, ADM (GC-FIN)



  49. Isabelle Jacques, ADM (GC-FIN)

    When we -- certainly when we developed the policy, we were focusing on those people involved in the illegal activities, and certainly in our discussions, daily discussions with the CBA and, you know, we had discussion with the RCMP, certainly these issues came to light. That was not the focus of the policy development. We understand that that was maybe some people were impacted, but we had discussions in the application to say our focus was certainly on these people involved in the activity.


  50. Isabelle Jacques, ADM (GC-FIN)

    That is correct.


  51. Isabelle Jacques, ADM (GC-FIN)

    I have no information to that effect.


  52. Isabelle Jacques, ADM (GC-FIN)

    That is correct. I wouldn't -- that's not information that I'd be privy to.


  53. Isabelle Jacques, ADM (GC-FIN)

    As a -- the Department of Finance did not receive any information to that effect.


  54. Isabelle Jacques, ADM (GC-FIN)

    It's not information that we would ---


  55. Isabelle Jacques, ADM (GC-FIN)

    --- to be received.


  56. Isabelle Jacques, ADM (GC-FIN)

    Can you pull up section 3?


  57. Isabelle Jacques, ADM (GC-FIN)



  58. Isabelle Jacques, ADM (GC-FIN)

    That is accurate.


  59. Isabelle Jacques, ADM (GC-FIN)

    That’s correct.


  60. Isabelle Jacques, ADM (GC-FIN)

    Yes. It can suspend dealings with those individuals and it could lead to the freezing of ---


  61. Isabelle Jacques, ADM (GC-FIN)



  62. Isabelle Jacques, ADM (GC-FIN)

    An account.


  63. Isabelle Jacques, ADM (GC-FIN)



  64. Isabelle Jacques, ADM (GC-FIN)

    Bank accounts.


  65. Isabelle Jacques, ADM (GC-FIN)

    That is true.


  66. Isabelle Jacques, ADM (GC-FIN)

    I don’t recall the CBA voicing concern with the scope of the orders. I do not recall that.


  67. Isabelle Jacques, ADM (GC-FIN)

    The scope, no, but the impact. I mean, one concern that was raised with respect to the impact it may have with respect to child support. That’s the only concern that I recall.


  68. Isabelle Jacques, ADM (GC-FIN)

    That’s very possible. And if they did, I would have said yes.


  69. Isabelle Jacques, ADM (GC-FIN)

    Well not for banks. I mean, we had ---


  70. Isabelle Jacques, ADM (GC-FIN)

    I mean, we had prepared some frequent questions for internal purposes, yes.


  71. Isabelle Jacques, ADM (GC-FIN)



  72. Isabelle Jacques, ADM (GC-FIN)



  73. Isabelle Jacques, ADM (GC-FIN)

    They were not being investigated. Yes. That was not the focus of their investigation.


  74. Isabelle Jacques, ADM (GC-FIN)

    Yes, they were captured.


  75. Isabelle Jacques, ADM (GC-FIN)

    And on those small donations, just to specify, yes, they were captured, but it’s important to note that certainly the Order was no retroactive. So any donations that would have been given prior to the Emergencies Act being enacted were not captured. And as we said previously, it’s important that you look at the context as to when we came about to draft the order, we didn’t know how the situation would evolve. But in the application of the order, certainly the focus was not on those donations.


  76. Isabelle Jacques, ADM (GC-FIN)

    Can we see?


  77. Isabelle Jacques, ADM (GC-FIN)

    It would be good just to read it.


  78. Isabelle Jacques, ADM (GC-FIN)

    Thank you.


  79. Isabelle Jacques, ADM (GC-FIN)

    "And what about people"? That one?


  80. Isabelle Jacques, ADM (GC-FIN)



  81. Isabelle Jacques, ADM (GC-FIN)



  82. Isabelle Jacques, ADM (GC-FIN)

    And certainly, we -- yeah, we told them to, and as they have, use their good judgement in applying this Order throughout, yes.


  83. Isabelle Jacques, ADM (GC-FIN)

    That I do not recall if they asked me that question.


  84. Isabelle Jacques, ADM (GC-FIN)



  85. Isabelle Jacques, ADM (GC-FIN)



  86. Isabelle Jacques, ADM (GC-FIN)

    When they had information -- yes. I mean, it was their ---


  87. Isabelle Jacques, ADM (GC-FIN)

    No, no. But do you mean - -- it's their responsibility to be compliant with the law, yes, and also, there is a clause that simply that they need to share information that they have with the RCMP and/or CSIS.


  88. Isabelle Jacques, ADM (GC-FIN)

    That is accurate.


  89. Isabelle Jacques, ADM (GC-FIN)

    It was their decision to make and do the assessment and consult internally, you know, and receive the proper advice on their decision.


  90. Isabelle Jacques, ADM (GC-FIN)

    I don't know if there was any such exercise of -- by the RCMP to review compliance with the Order. I've never heard that in the past.


  91. Isabelle Jacques, ADM (GC-FIN)

    It was to provide for the information-sharing to help the RCMP and in pursuing some maybe investigation, yes.


  92. Isabelle Jacques, ADM (GC-FIN)

    Not to go back -- not for the RCMP to take account. That was not the purpose. It was to share information to allow the RCMP to do their job.


  93. Isabelle Jacques, ADM (GC-FIN)

    I -- it was not intended that way. I find that to be a stretch.


  94. Isabelle Jacques, ADM (GC-FIN)

    From the CBA, yes.


  95. Isabelle Jacques, ADM (GC-FIN)

    Certainly, we provided the information, usually via Michael.


  96. Isabelle Jacques, ADM (GC-FIN)



  97. Isabelle Jacques, ADM (GC-FIN)

    Certainly. I mean, looking at it -- you know, one of the key points that we did look at at the outset when drafting, and you must understand we were working on this fairly quickly, looking at a de minimis amount. But you also understand that a number of people were donating small amounts to crowd funding platforms; right? And so there was always that possibility. But looking at it, if we were to do it, I think we could craft some exceptions for the application for very specific cases. It’s not something that we did in the time that we had, but I don’t disagree with you that it’s something, you know, in hindsight that we could look at in being more specific in that regard, because the intent was not to effect -- unduly effect, you know, payments of child support or other payments.


  98. Isabelle Jacques, ADM (GC-FIN)

    But you’re talking about people here that were involved in unlawful activities.


  99. Isabelle Jacques, ADM (GC-FIN)

    VR Regulation.


  100. Isabelle Jacques, ADM (GC-FIN)

    I do not ---


  101. Isabelle Jacques, ADM (GC-FIN)

    Yeah, I didn't want to reply for ---


  102. Isabelle Jacques, ADM (GC-FIN)

    --- Michael, but we could have never drafted and passed those regulations in those timelines.


  103. Isabelle Jacques, ADM (GC-FIN)

    It seems very simple because, you know, you see the drafting of the amendments, it doesn't seem to be very long, but the process to pass a regulation it's not something that you can do in the timelines that we had to enact and work on the Order.


  104. Isabelle Jacques, ADM (GC-FIN)



  105. Isabelle Jacques, ADM (GC-FIN)

    I mean, we had been working in the previous week on a couple of options. One, as we said, with respect to amending the Bank Act, and the other when we heard later, much later in the week, that it was possible that the Emergencies Act would be invoked, we started working on potential orders.


  106. Isabelle Jacques, ADM (GC-FIN)

    I certainly did not, nor did any member of my team, consult with Provincial Government.


  107. Isabelle Jacques, ADM (GC-FIN)

    We did not consult.


  108. Isabelle Jacques, ADM (GC-FIN)

    Well I became aware at one point in time that there was some misinformation with respect to small donations. People thought that donations that had been made prior to the Emergencies Act being enacted would be subject of potential freeze.


  109. Isabelle Jacques, ADM (GC-FIN)

    I have not seen -- let me see. I have not seen the beginning of the ---


  110. Isabelle Jacques, ADM (GC-FIN)

    --- Q and A document, but -- and at the bottom, does it say that it was prepared by Canada? Of the document. We can’t see it on the screen.


  111. Isabelle Jacques, ADM (GC-FIN)

    All right. Thank you. Okay. Thank you.


  112. Isabelle Jacques, ADM (GC-FIN)

    No, I understand your question. I do not know when this was prepared. I don’t know if there were -- I suspect that there may have been discussions, I know there were discussions with various associations, insurance associations, so I do not know if it’s as a result of those discussion that this answer was provided.


  113. Isabelle Jacques, ADM (GC-FIN)

    Well insurance is ---


  114. Isabelle Jacques, ADM (GC-FIN)

    No, they were not consulted about ---


  115. Isabelle Jacques, ADM (GC-FIN)

    Afterwards, yes.


  116. Isabelle Jacques, ADM (GC-FIN)

    Well, what I understand is that they made a decision not to share any information with respect to people that own vehicles that were involved in the illegal activities, and I would, you know, say that that was, in my view, the right decision. The purpose when we drafted the policy and the law -- I mean, as we have said many times, one of the intent was to encourage people to leave and stop the illegal activities in which they were engaged.


  117. Isabelle Jacques, ADM (GC-FIN)

    Good afternoon.


  118. Isabelle Jacques, ADM (GC-FIN)

    These were no ordinary events, that is accurate.


  119. Isabelle Jacques, ADM (GC-FIN)

    Yes, we wanted to see if we had any tools in place that could be useful ---


  120. Isabelle Jacques, ADM (GC-FIN)

    --- from a financial perspective.


  121. Isabelle Jacques, ADM (GC-FIN)

    Well, certainly, that triggered our interest as -- you know, as people are starting to donate via crowdfunding platforms, we were looking at that. But, you know, it was to support what was a peaceful event.


  122. Isabelle Jacques, ADM (GC-FIN)

    Well, at the time when we found out, we -- well, I suppose it was maybe surprising but we were right in the middle of budget at the time and when we -- we just basically read news articles that were incoming.


  123. Isabelle Jacques, ADM (GC-FIN)

    Well, I couldn’t tell you how many people donated because you can’t tell the size of the donations, so -- but -- I mean the amount was substantial amounts, yes.


  124. Isabelle Jacques, ADM (GC-FIN)

    Well, as we said, we knew that in the past, from our work with the international association organizations that, you know, crowdfunding platforms and some -- most payment service providers were not captured by the legislation.


  125. Isabelle Jacques, ADM (GC-FIN)

    That’s right.


  126. Isabelle Jacques, ADM (GC-FIN)

    Yes, it does.


  127. Isabelle Jacques, ADM (GC-FIN)

    If it was paid to the bank, yes.


  128. Isabelle Jacques, ADM (GC-FIN)

    Well, I mean the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, I mean, applied at the time, so if information was being provided to FINTRAC, I wouldn’t have known about that.


  129. Isabelle Jacques, ADM (GC-FIN)

    So it’s possible that information was being shared. I do not know.


  130. Isabelle Jacques, ADM (GC-FIN)

    Again, I can’t say that. I do not know what information was shared. I don’t -- FINTRAC would know if any information at the time had been shared with them.


  131. Isabelle Jacques, ADM (GC-FIN)

    That’s accurate.


  132. Isabelle Jacques, ADM (GC-FIN)

    Yes, unlawful act, yes -- activities, yes.


  133. Isabelle Jacques, ADM (GC-FIN)



  134. Isabelle Jacques, ADM (GC-FIN)

    I -- but we were not engaged in drafting the regulations. So we were engaged in what became the Economic Measures Order but not the regulations.


  135. Isabelle Jacques, ADM (GC-FIN)

    Of -- of the -- of what is described as, as you -- I think you were just saying, “illegal activities”. Let me see. You’d have to bring me the -- you know, we didn’t work on those regulations, so which section were you referring to, sorry?


  136. Isabelle Jacques, ADM (GC-FIN)

    Correct, yes.


  137. Isabelle Jacques, ADM (GC-FIN)

    No, but I don’t see the link, I must admit.


  138. Isabelle Jacques, ADM (GC-FIN)

    I’m not sure that -- to see the link. What is your question?


  139. Isabelle Jacques, ADM (GC-FIN)



  140. Isabelle Jacques, ADM (GC-FIN)

    I mean all that that did was to extend the -- so under the PCMLTFA, the only requirement was -- nothing was changing in the Act other than to extend to crowdfunding platform and payment service provider the obligation to register if they were in position of property that were own by those designated people. So it was a very narrow application.


  141. Isabelle Jacques, ADM (GC-FIN)

    Not to my knowledge, no.


  142. Isabelle Jacques, ADM (GC-FIN)

    Well, no, not frustrating. I mean we’re trying to help -- you know, all departments were trying to help to find solutions.


  143. Isabelle Jacques, ADM (GC-FIN)

    Well, under the -- well, it’s not to stop donations. That was not the purpose, but certainly -- I mean we didn’t have the tools to direct, you know, financial service providers to review their relationship with their clients or to freeze bank accounts, and certainly, we didn’t end the Act, the PS -- the Proceeds of Crime, Money Laundering, and Terrorist Financing Act did not apply to a crowdfunding platform and certain payments that was provided.


  144. Isabelle Jacques, ADM (GC-FIN)



  145. Isabelle Jacques, ADM (GC-FIN)



  146. Isabelle Jacques, ADM (GC-FIN)



  147. Isabelle Jacques, ADM (GC-FIN)

    That’s what I heard in the news.


  148. Isabelle Jacques, ADM (GC-FIN)

    Again, I have no personal knowledge, but yes, I read that.


  149. Isabelle Jacques, ADM (GC-FIN)

    I would imagine.


  150. Isabelle Jacques, ADM (GC-FIN)

    I suppose so, yes.


  151. Isabelle Jacques, ADM (GC-FIN)

    I don’t agree with that. I mean, people can make donations and could still make donations. The only restriction that were imposed was to support illegal activities.


  152. Isabelle Jacques, ADM (GC-FIN)



  153. Isabelle Jacques, ADM (GC-FIN)

    Well, at the time, you know, we didn’t know what was happening with TD Bank for sure, but it doesn’t mean that because there's let's say actions taken one place that money will not be funnelled through other ways. I mean, money is fungible.


  154. Isabelle Jacques, ADM (GC-FIN)

    That's accurate.


  155. Isabelle Jacques, ADM (GC-FIN)

    Yeah, we had this -- we had discussion with Public Safety before the measures were enacted, yes.


  156. Isabelle Jacques, ADM (GC-FIN)

    No, we did not.


  157. Isabelle Jacques, ADM (GC-FIN)

    No. Actually, we're provided the -- we have measures so that -- to ensure that information could be exchanged between the RCMP and financial institutions.


  158. Isabelle Jacques, ADM (GC-FIN)

    That's -- yes.


  159. Isabelle Jacques, ADM (GC-FIN)



  160. Isabelle Jacques, ADM (GC-FIN)

    Well, I think banks and financial institutions on a regular basis use their algorithm to, you know, detect fraud, you know, for example, fraudulent activity in credit cards, or bank accounts even, you know, important withdrawals. So on a regular basis, they have tools to detect these activities and to freeze either the bank account or the card pending resolution of the inordinate activities on the account.


  161. Isabelle Jacques, ADM (GC-FIN)

    That's correct.


  162. Isabelle Jacques, ADM (GC-FIN)

    That's right.


  163. Isabelle Jacques, ADM (GC-FIN)

    I presume that that would be possible, yes, especially such a large amount.


  164. Isabelle Jacques, ADM (GC-FIN)

    That's correct.


  165. Isabelle Jacques, ADM (GC-FIN)

    Absolutely, and that was an important part of the policy work we did. We wanted to ensure that financial institution had an ongoing obligation to review the information that they had, specifically for that, so to ensure that they can, you know, freeze or unfreeze account based on the information that they have.


  166. Isabelle Jacques, ADM (GC-FIN)

    Well, it was very important because, you know, we didn't know who was donated in which province to where. Also, I mean, we had heard that funds were coming from outside of Canada. So if funds are coming in, we don't know where they -- where it's going to come in Canada and where it's going to go, so it was very important that as money flows that we could have a consistent approach across the country and ensure that the funds that were used to support those illegal activities were frozen.


  167. Isabelle Jacques, ADM (GC-FIN)

    Yes, we had been informed that the RCMP had been, you know, informing people, certainly on the Hill, I don’t know elsewhere, that the freezing of bank accounts were a possibility if they weren’t leaving the location where they were at.


  168. Isabelle Jacques, ADM (GC-FIN)

    Well, we had -- it was, again, twofold. I mean, it could have been just based on a person -- say, a person leave and cease his illegal activity could, you know, contact the bank and tell them that they were no longer involved and that they were no longer on location and/or, you know, via a person could have gone maybe to the RCMP, get in touch with law enforcement to ensure that the information was conveyed to the financial sector.


  169. Isabelle Jacques, ADM (GC-FIN)

    Yes, that is accurate. As soon as a person ceases the activity, the account could be unfrozen. So as quickly as we could freeze -- the account could be frozen, it was easily unfrozen.


  170. Isabelle Jacques, ADM (GC-FIN)



  171. Isabelle Jacques, ADM (GC-FIN)

    Well, we don’t have that detail of information. It’s impossible, and it was difficult for us to draft a measure in such a way.


  172. Isabelle Jacques, ADM (GC-FIN)

    Well, I mean, the Ontario Order was one circumstances but it was -- for us, you know, there was always a risk that funds could be given to another crowdfunding platform using other payment service providers, money, you know, as we said, can be flown from different ways, could have ended up in wallets. I mean, we did not know at the time. So the fact that it was one Court Order doesn’t solve the situation. So it was important that we take the measures we took.


  173. Isabelle Jacques, ADM (GC-FIN)



  174. Isabelle Jacques, ADM (GC-FIN)

    That’s right.


  175. Isabelle Jacques, ADM (GC-FIN)

    Well, I mean, we were aware that some money were being flown to cryptocurrency wallets, and so we wanted to ensure that that was captured as well.


  176. Isabelle Jacques, ADM (GC-FIN)

    Yes, I heard about that.


  177. Isabelle Jacques, ADM (GC-FIN)

    I mean, certainly as we mentioned before, I mean, if we would have -- we’d had more time to draft and craft the policy at the time, maybe to provide some specific exceptions to -- for some sum of money for the freezing of the bank accounts, maybe that is something that we would have done. Certainly with respect to the list of designated person as we -- as it was mentioned, I mean, I know that although there was no provision for listing, effectively the RCMP provided a list of person to financial institutions. I mean, that’s something that we can think about, but we also do not want to lose the capacity of financial institution to do their own verification. I think that is still key. So maybe it’s something that we could think about as to how we create this procedure to share a list, but we’d have to think about that further.


  178. Isabelle Jacques, ADM (GC-FIN)

    Thank you.