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Aside from a possible World Series victory for the Blue Jays, an upcoming evaluation by the Financial Action Task Force, perpetually evolving sanctions and pending anti-money laundering reforms were top of mind at The Assembly Canada in Toronto.

One such proposal, Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, would raise maximum penalties the Financial Transactions and Reports Analysis Centre of Canada, also known as Fintrac, can impose by as much as 40-fold and newly require all companies with AML obligations to register with the agency.

“We are expecting Bill C-12 to pass along with the budget on Nov. 4,” Michael Garellek, a financial and securities lawyer with Baker & McKenzie in Toronto, said during the opening panel Wednesday. “The bills and the measures that the government is proposing show that attacking money laundering and terrorist financing is a priority.”

The measures aim to address shortcomings identified during FATF’s most recent evaluation of Canada nearly 10 years ago, in 2016, with the exception of the country’s legal sector, which will remain outside the scope of anti-money laundering obligations indefinitely.

“It’s timely that we are seeing some of these measures …, [but] there are still gaps,” said Suhuyini Abudulai, a partner at Borden Ladner Gervais in Toronto. “Legal services, for example, have been identified as a significant gap that the regime still does not cover.”

Bill C-12 would account for another area that FATF identified as a weakness in 2016, namely, financial-intelligence sharing, by authorizing Fintrac to disclose more information to law enforcement, other government agencies and financial institutions.

In doing so, the legislation would build upon the authority granted to banks last year to share intelligence with each other on suspected instances of money laundering, sanctions evasion and terrorism finance.

“These efforts are meant to enhance private-to-private, private-to-public and public-to-public information-sharing,” Kevin Brosseau, Canada’s “Fentanyl Czar,” said in Wednesday’s keynote address. “Information should be shared with those who can act upon it—on one day, this could be financial institutions, and on another day, a police officer.”

Canada’s largest banks have struggled to define when and in what context they can share confidential details of customers and their transactions under the voluntary framework.

“I don’t think there is really a roadmap for what the legislative pathway would be for private-to-private information-sharing in Canada,” Nathalie Martineau, a senior compliance officer at TD Bank, told attendees Thursday. “It’s a very iterative process, we’re learning this, [and] Fintrac is developing this for the very first time as well.”

The Canadian government’s disclosure days before the conference of a plan to create and task a new agency exclusively with investigating illicit finance also made the agenda.

“There is some debate as to whether they would have its own unique case files, or … collaborate with other organizations,” Ted Gallivan, interim deputy national security and intelligence advisor to Prime Minister Mark Carney, told attendees Wednesday. “My own view is that they would pursue the most serious cases and have a multi-disciplinary team to do so.”

Gallivan also identified youth radicalization and domestic terrorism as major threats, and encouraged financial institutions to rely on “non-financial indicators” such as social media activity and crowdfunding behavior to identify and disrupt them.

Other panelists discussed Canada’s latest export restrictions against Russia and designations targeting the country’s shadow fleet of oil tankers, and decision to blacklist dozens more individuals and entities financing or otherwise supporting Iran’s Islamic Revolutionary Guard Corps.

The designations have brought Canada mostly in line with the U.S. and other allies, Andrii Dzhaga, a global sanctions officer at Stripe, told attendees Wednesday afternoon.

Canada is still playing catch up in dismantling financial and commercial restrictions against Syria, however.

“Many of you in the room may not be considering expanding into Syria, but your clients will,” said John Boscariol, partner at McCarthy Tetrault in Toronto. “As their competitors in the U.S., Europe and the U.K. now have more flexibility to go into Syria, Canadian companies won’t have that, or they may not have clarity, because there is less guidance here.”

Canada’s recent designation of seven Latin American drug cartels as terrorist organizations also marked a significant change in the sanctions landscape, even if little has changed procedurally.

“We see new sanctions listings every single day,” Stephen Alsace, global head of economic sanctions, anti-bribery and anti-corruption at the Royal Bank of Canada, said Thursday afternoon. “But how you deal with it is a little bit different.”

Faced with mounting regulatory pressure and global concerns over gold’s ties to armed conflict, human trafficking and illicit finance, financial services companies in Canada and across the world have ceased onboarding customers in the sector and exited existing relationships.

Rather than decoupling themselves entirely from gold, however, banks and other financial services companies should expand their due diligence beyond the refineries, mining companies and other parties they serve directly to encompass the “asset class,” Andrew Naylor, head of public policy at the World Gold Council, told attendees.

“For banks doing due diligence on gold-related counterparties, information on what will trigger a [suspicious transaction report] is quite limited, and it is limited largely to the direct counterparty,” said Naylor “We should pay attention to where the gold comes from, and who has produced, processed and traded it.”

Separately, Canada may follow the U.S. Office of the Comptroller of the Currency and other federal regulators in embracing cryptocurrency.

“[The OCC’s guidance] in tandem with the removal of the reputational risk standard for regulation in the U.S. is a big deal, and I expect there will be some continuation of that across the border into the Canadian system,” Jane Bell, a senior industry consultant, said.

And that’s a wrap.

Contact Chelsea Carrick at ccarrick@acams.org