S3/E2: Anti-Money Laundering and Asset Recovery, with Jeffrey Simser

Introducing Jeffrey Simser and Episode on Financial Crime Welcome to the Financial Integrity Hub podcast. At the Financial Integrity Hub, we lead research into the legal and governance frameworks that underpin effective responses to money laundering, terrorism financing and proliferation financing. This podcast is proudly sponsored by Arctic Intelligence, a multi award-winning Regtech firm specialising in financial crime risk orders and compliance software. Trusted by regulated businesses in over 25 countries, Arctic Intelligence delivers highly configurable cloud based AM, LCTF and financial crime risk assessment platforms and content that help organisations better identify, assess, mitigate and manage financial crime risks. Speaker 2 Welcome to the Financial Integrity Hub podcast, the show with hot questions and even hotter insights at the intersection of law and financial crime. I'm your host, Doctor Hannah Harris, and today we're joined by Jeffrey Simpson. Jeffrey is a Canadian lawyer and one of the leading architects of Canada's civil forfeiture and asset recovery regime. Jeffrey served as Legal Director at the Ministry of Attorney General in Toronto and was Canada's first Director of Civil Asset Forfeiture. With more than 30 years experience working at the intersection of anti money laundering, asset recovery and public policy, Jeffrey has published extensively on anti money laundering law in Canada and continues to provide expertise and support to law enforcement agencies across Canada and around the world. As we know, financial crime is a global challenge. But illicit financial flows are no longer about suitcases full of cash trapped under car seats. They're about value transfer, moving invisibly through tangled networks that stretch from cartel linked markets in Mexico to underground value transfer systems in China. Meanwhile, regulators and courts, as well as law enforcement agencies continue to grapple with how to keep pace. Australia and Canada are in the thick of it. Both jurisdictions share a federal structure, common law tradition and sophisticated financial service sector. Both countries are participating in the current round of Financial Action Task Force mutual evaluations, and both countries have experienced deploying innovative legal mechanisms like civil asset forfeiture and unexplained wealth orders to combat financial crime threats. In today's episode, we unpack where AML law has been, where it's headed in what Canada, Australia, and the global community can learn from each other in the fight against illicit finance. The hardest part of my conversation with Jeffrey today was bringing it to a close. I thoroughly enjoyed our chat and I'm delighted to share his insights with you today. Remember, as always, if you haven't already, please like and subscribe to the Financial Integrity Hub podcast on Spotify and YouTube, and follow the Financial Integrity Hub on LinkedIn to stay up to date with the latest insights in upcoming events. Speaker 3 Hi, Jeffrey. Speaker 2 Welcome. Thank you so much for joining us today on the podcast. Speaker 4 Thanks for having me. Speaker 3 I'm really excited to share with our audience today your really unique experience and some of your expertise. Speaker 2 As well as your specific. Speaker 3 Expertise in the Canadian jurisdiction, which is not an area I'm particularly familiar with. And I know for our listeners also, they're really keen to get more of a kind of global perspective on some of these topics around financial crime. So really appreciate you joining today for that reason. Would you be able perhaps to give our audience a little bit of insight into your professional journey so far and how you arrived where you are today? Understanding Civil Asset Forfeiture in Combating Crime Sure. So I'm, I'm a lawyer and I, I spent 32 years in the public service working for the attorney General here in, in Toronto, in Canada. And about 1/4 century ago, I, I was in a briefing with the attorney General at the time, the late James Flaherty, and he asked a question about an American law called Rico, which is the Racketeer Influence Corrupt Organizations Act. And no one in the briefing room knew the answer to his question. But being foolish and a little crazy like I am, I said I will look it up. And that's what literally started my journey into this area of financial crime. I've been a barrister, solicitor, a corporate commercial lawyer, and I've done a lot of policy work in the government. But financial crime was new to me to be able 26 years ago. And, and it's sort of developed into this nerdish affliction that I still have. I retired from public service and I'm in private practice now and I represent a couple of jurisdictions in Canada and give them support and advice. And so I'm I'm still in the game and, and enjoying it. It's one of those things, financial crime, For those of you who are into it, understand that what you kind of get bitten by the bug, it follows you everywhere. Speaker 3 Yeah, For me, it was raining midnight in Sicily in my honors year and then it was all downhill from there. Or if you want to look at it. But I mean, and if law can be iconic, Rico is definitely that now. But interesting for you to have that historical experience of being largely unknown globally. Whereas it was such a catalyst for, I think, so much of what we consider now to be a unique approach or an important way to address aspects of crime that were previously off the radar, I guess. Speaker 2 Could you speak briefly to the role of asset? Speaker 3 Forfeiture in the wider. Speaker 2 Landscape of. Speaker 3 Financial crime prevention and enforcement action. Speaker 2 In your view, why is asset forfeiture such an? Speaker 3 Important tool to combat financial. Speaker 2 Crime and what is special about non conviction based forfeiture regimes like those we see in Canada? Speaker 4 So asset forfeiture, what I realized when we started to get into it, first of all, that my area of, of, of expertise is around what we call civil asset forfeiture in Europe as non conviction based forfeiture. And what we realized was the criminal justice system is so burdened right now with the obligations of disclosure and it's under resourced. And there are lots and lots of malign actors who know that and who take advantage of it, who who deliberately organize their affairs to evade any kind of criminal justice sanction to them. And so asset forfeiture is really, really important because most financial crime, all financial crime really is committed to make profit and to launder that profit into some sort of a form where you can appear to be a legitimate, legitimate business person. And so asset forfeiture is a really, really important tool. It's not everything. There are people that ought to go to jail and do go to jail, but it is an important component of of sort of solving some of the the problems that plague us in society right now. Speaker 2 Thanks Jeffrey so for. Speaker 3 Listeners who may not be familiar with the mechanics. Speaker 2 Of how civil asset. Speaker 3 Forfeiture actually operates in Canada. Maybe you could speak a little bit to how that works and maybe some history and how it's evolved over time. Speaker 4 Sure. So we Canada is a lot like Australia and New Zealand. We have common legal traditions. And it's very interesting because I can read Australian law and it makes sense to me in the context of how Canadian law works. And hopefully for your listeners, they'll feel the same way. So in Canada, we have a federal system and the federal government, the national government is responsible for passing criminal law. And provinces and territories are then responsible for administering criminal law, but also for passing all laws related to property and civil rights. And when we started, when I started a civil forfeiture, I was the first director of civil forfeiture in Canada. Lots and lots of lawyers, particularly defense lawyer said I couldn't do it because civil forfeiture was really punishing A person by taking away their stuff. And we always took the view that no, that's not so that if a bank robber is standing on the on the steps of a bank with a cartoon cloth bag with a dollar sign on it, that bank robber has no claim to the money in that bag. It belongs to the bank. And we also in in in the provinces, in the territories in Canada, we define how you get to own something and then and all of the rights that kind of go with this. And So what a civil forfeiture law says in essence, is that if we can prove, prove in the court that you have obtained this money as a proceed of unlawful activity of crime, you can't own it. And the law property doesn't like to have any kind of a void. And So what we do is we say no problem, it will be forfeited to the state. And in our case in in a province. So there's 10 jurisdictions in Canada that have a form of of civil forfeiture law. There's a couple that are coming Northwest Territories in the Arctic are are working there, said that publicly. They're working on a law right now. And essentially there are two kinds of property that it goes after one are proceeds. So that is money that has as its origin or provenance any kind of a crime. And then there's instruments. So that's property that makes the labor of the crime possible. So you could have the the bag of cash from the robbery and the getaway car. Even though the getaway car was bought legitimately, if it's being used as that, then it is an instrument in our law. Sometimes you hear instrumentality of the crime. So those those are basically the tools. And that's basically how civil forfeiture works in Canada. Canada's Asset Forfeiture: Evolution, Resources, and Impact It's fantastic and I think definitely our audience will see some parallels with both the structure of Australia, which makes it a great comparative law case study. I've done that in areas like securities and equities markets as well because their regulatory frameworks need to kind of line up on that regard to. But yes, it's great to have this nice comparison jurisdiction. We're allowing our listeners to get a global perspective while keeping it a little close to home in terms of that structure. How long has this been around in Canada? And I think partially because of the system, you have noted that there's been a large uptake, but there are still some States and territories coming on board. What is kind of the longest existence versus the newest and and how has maybe that environmental dynamic being shaped would have been the sticking points or the kind of momentum generation? Speaker 4 Yeah, So it's interesting. It's, it's hard to know the politics behind each jurisdiction as to when they pass a law. The law that I, I wrote of 26 years ago is the first, it's still the first in Canada, although the jurisdiction that I used to work for isn't probably the leading one, which is, which is unfortunate. About 95% of the Canadian population is covered, but there are some outliers that provinces like Newfoundland and Labrador as well as Prince Edward Island, the Yukon and the Northwest Territories are, are not yet there. And we'll talk in a little bit probably about the Financial Action Task Force in the evaluation. I suspect that'll be one of the recommendations that it makes is that we have consistent coverage terms of old and new. I mean, it's constantly evolving. The most recent, a major reform of a, of a jurisdiction was Nova Scotia, which in December passed, well actually passed it in the legislature in October and brought it into force in December, a completely revised version of their civil forfeiture law. It was about 15 years old or so, but it hadn't really been used. And so they've brought it up to speed, made it something that maybe an Australian law enforcement official would recognize, and that have brought that into force. Speaker 3 That's really fascinating. And I think your point in general about you can pass these laws and they might have the same kind of purpose or intent, but depending on how they're structured and also I guess how they're chosen to be implemented or enforced, they can have different levels of effectiveness or different application or not at all. What are, do you think, some of the kind of key features of these types of law that make them more effective rather than less that you've seen in your experience? Speaker 4 Yeah. So I, I think the number one is, is really, it's a, a resourcing choice for the government that has the law because Nova Scotia and New Brunswick had laws on the books for a long time, sort of the province of Quebec, which is a very unusual law because Quebec has a, a French civil legal system that goes back to Napoleon. So it's, it's actually a very unique law that would be more familiar to someone in Italy and France than it would be to someone in Australia. Really the, the key factor is how a jurisdiction Staffs up their unit. So in Ontario, where I am now, they just throw it into a general litigation function. And so everything from slip and fall to whatever kind of civil litigation that involves the government, civil forfeiture, just kind of part of that. And it has not been effective in jurisdictions like British Columbia where they have a, a structure, they have a director, they have teams, they have specialized litigators, they have specialized analysts. Those have been much, much more successful. It's not quite like, say, the NSW Crime Commission, but it's moving along to that, to that model. But one of the things that we really are careful to do is to keep the policing function and the prosecutorial function separate from the civil law function. And part of that is just for constitutional risk as much as it's anything else. Speaker 3 Yeah, fascinating. And I'm, I'm trying not to geek out too much because I know our audience is diverse and they don't just care only about what I care about. But I would quite happily just talk about those kind of focused approaches to enforcement and ensuring that you have specialized teams. And because from my anti bribery background and my corruption background as well as similar issues, it's like if we think just about crime broadly, then we miss a lot of the important subtleties and opportunities that exist to prevent, to detect, to enforce. And I mean, obviously as it forfeiture is an important component of the anti corruption space as well. But even within that, to hear you talking about, depending on where you house something like this and tools like this, you get different levels of effectiveness. It's exciting, fascinating for me. I don't get it. Speaker 4 Yeah. No, no, no. I'll stay with the digression just for a second. Typically police forces are looking at looking at a an issue from them, a particular lens. For example, there was a murder case in Vancouver. They were focused on getting the shooter, but there were lots of proceeds of crime aspects that came up in that case. And So what they did was they simply parsed it off. It wasn't their main area of investigative focus. So it was given over to the civil forfeiture authorities. They actually launched an unexplained wealth order, which they obtained to explain several $1,000,000 worth of, of assets. They were drug related. They might have been able to do the case without the UWO, but the thing about that one was that the investigation really wasn't focused on the proceeds other than to figure out who fired the gun, that sort of thing. That's really what the the police were focusing on. So that's sometimes why you want that specialty area, because then you can sort of focus on one aspect, which is just the proceeds of crime. Speaker 3 Yeah. I mean, in a fantastic point too, to remind us all, I think I can sometimes be guilty of this thinking about financial crime as its own kind of specific type of crime and then bringing it back and attaching it to the predicate offenses and remembering that violent crime has proceeds. Violent crime is committed for profit as much as anything else. Unexplained Wealth Orders and Asset Cloaking Techniques It's not only these kind of esoteric forms of of criminality that are financial crime. So I appreciate you sticking with that digression. Speaker 4 And we're, we're seeing it's current affairs. I don't know how when this is broadcasting, but we're seeing right now in Mexico and Western Mexico, lots of violence and really that's related to a cartel and that their, their leader was killed and they're reacting with violence. But that cartel is there to make money and they're, they're there to profit. And so there always is a link. And if you're in an organized crime figure, you don't go to call, call the police if you have a problem. You have to self enforce. And in that world, often violence is involved. Speaker 3 Yeah, fantastic illustration. And I think that also brings me to another aspect of this that I wanted to speak to, which was when we're talking about the profit element, this idea of unexplained wealth orders which are evolving I think globally. But I think Canada is also experimenting with these or considering that experiment in different areas. Australia has a framework in place. The UK has utilized it as well. Maybe you could give your? Speaker 2 Perspective on the potential of. Speaker 3 This type of mechanism and also limitations or some of the challenges that you think we need to be aware of here. Speaker 4 Yeah. So there there's 4 jurisdictions in Canada that have a UW O process. There's only two that have used them. One is Manitoba. There's a case where a priest was stealing from a Sikh temple and they use that because he had all kinds of assets that we no one really understood how he came to have them. British Columbia, though, is really the leading jurisdiction in that space and they used it in a really interesting case. There was a securities fraud involving the guy named Kevin Miller. He bounced the proceeds of the fraud across a couple of of shell companies in Panama and the Marshall Islands. It ends up in a Vancouver lawyers trust account and the the lawyers actually the first lawyer in Canada disbarred for money laundering guy named Ronald Pelcher. And when he's disbarred, then Mr. Miller, whose funds were in his trust account, asked for them back. And so that's a case where a UW O was sought and he brought a very good lawyer into the court and they challenged and he said it's an unlawful search and seizure. And he threw every argument, I guess that he could at the thing. And the court disagreed and said no, no, no, this is a perfectly legitimate information gathering process. It's over in the Canadian process. It's overseen by the court. So UWO is a court order. The person seeking it, which typically is a director of forfeiture, must satisfy a number of tests to do it. It's not a perfect magic bullet, but in a case like that where money's hopped across jurisdictions where it's very, very difficult to do all of the tracing, what the UWO really does is it puts it to the person whose bet is the best knowledge of where that money came from and asks him to to explain how that money came to be in that lawyer's trust account. Speaker 3 Yeah, fantastic. And don't we love it when people actually choose to challenge some of these pieces of law so that we can get that backing, that support from the courts? So this actually does stand up and. And here's why. And I think you made the point there also that one of the things with unexplained wealth orders and similar instruments is that they do shift the kind of burden onto the party that we can assume knows how they did what they did. And sometimes what they did is quite complicated. Yeah. So I think you've written and spoken in other areas about kind of asset cloaking techniques and the idea of informal value transfer systems, which I think maybe are related in some ways to this because this complexity makes it more important for us to be able to say, hey, you need to prove why this is legitimate. I wonder if you could speak a little bit more maybe to that dynamic of asset cloaking as a tool of financial crime and how some of these more recent evolutions such as cryptocurrencies and and digital platforms are affecting those dynamics. Unpacking the Threat of Chinese Underground Value Transfer Yeah. So I mean asset cloaking is pretty simple in the in and it's not it. It's simple because the professional money launderer understands that a police force, a civil forfeiture authority, a prosecutor has to stay really within their national jurisdiction and the money launderer does not. And so they understand that if they can move from a high risk jurisdiction like Australia or Canada into a lower. More risk. South Pacific Island, someplace in the Caribbean, if they can make that movement, it puts up a barrier. It's not an immutable barrier, but it it adds friction and it makes the job of the investigator more difficult. And the hope and the aspiration of the of the malign actor is that police will just give up or that they won't get the approval or you just want a trip to go to the Bahamas or to the Solomon Islands or whatever it is. So that's, that's kind of the design around around asset cloak cloaking. And we're seeing things like crypto crypto's a really interesting one where it can move pseudo anonymously. It's not always and everyone has the sense that it's anonymous. No, it isn't. The problem though, with crypto if you're a criminal is it's incredibly unstable. Bitcoin can move in value in 10% in a day easily, if not more. And so it's not really a great investment vehicle and it's not really very good for sort of paying couriers and all that kind of stuff. What would tend to see is that becomes a very good rail. So it's a way of moving money, say from Dublin to Dubai. You move it through a crypto rail and then you, you transform it in into something else. It's the same with cash collection networks. You you take them from there's a 11 interesting typology involves moving cash into a a low a low jurisdiction like Zimbabwe, which has as a fairly unregulated gold market. You take the American dollars, you buy gold and then you export the gold back to a place like Dubai and then you enter it into into the financial system. I think, and we'll talk maybe later about the bigger risks. I think the biggest, biggest risk that we all face, especially in Canada and Australia are Chinese underground value transfer systems. And there's there's a a really massive underground banking system. I don't think we really have our heads around all of it. And that's something that's just moving just Titanic amounts of money around right now. Speaker 3 OK, why wait? Let's jump in right there. Can you maybe expand on that for our listeners a little bit more and tell us what what are we talking about here? What is the size? How are we trying to measure it? Where are we at? Speaker 4 Yeah. So I'll, I'll use a Canadian example just because it's the one that's most familiar to me. And so to, to set the context for this, two things happened around just over a decade ago in China. They were really worried about flight capital. They called the, the measures that they, they passed anti corruption measures, but they really put strong restrictions on how much money could leave the People's Republic of China because they were worried about how much money and even at that time that was leaving. And what that means is if you're a legitimate business person, you make the stuff in a factory that's being sold in, in Australia and Canada and what have you, you're making legitimate money, but you can't get it out of the country. And you might want your kid to go to school in Sydney or Vancouver. You got to figure out a way of getting the money out of the country. So there's this massive demand within the country because of that law, which wasn't really intended to create the demand, it just did. Then you've got a demand, a problem in Mexico, which is a different problem. So about 12-15 years ago, the behest really of Washington, the Mexican government changed their banking laws and made it more difficult to deposit U.S. dollars into a Mexican bank account. Again, the idea was to create a barrier, but what it also did was create this, this demand and it all of these things really been displaced, these transactions. So, so to give you an example of how this all comes together, you have a a drug dealer in Vancouver with a suitcase full of money. They will contact a cash collector network and they will give that money to someone that wants it in Vancouver, might be a legitimate Chinese business person. They want that money. That Chinese business person will in real time make a transfer within China so that the broker gets paid for the cash. There might be a manufacturer in China that produces precursor chemicals going to the cartels in Mexico. There's a debt to settle there that gets settled. And the money that is in that suitcase is drug money that really belongs to the cartel because they've exported drugs up to Vancouver and sold them. And so you get this whole circle, everything's reconciled. It's all done on encrypted communication. It's all done in real time. And it even though the, the, the professional money launder broker in the middle is, is clipping his ticket at all ends. That means it's incredibly cheap. And so it has displaced the way that Colombia, New Mexico cartels launder their money totally. They don't do it in the house. They don't need to. It's a lot cheaper, it's a lot safer. And the professional money launderers actually guarantee that if law enforcement happens to pick up one of the bags of cash and they insure, they said, don't worry, we'll make you whole even if you get ripped off and or you get knocked off by the police. So it's a very frightening ecosystem. Speaker 3 It is. It's, it's amazing to me how crime and the cat and mouse between crime and enforcement produces these very intelligent, very sophisticated, very complex systems that we then have to continue trying to get our heads around and to combat. Sounds scary. Can we think of or do you have any examples of how we are addressing this or any opportunities you think that are there? I'm thinking to the future also about the impending financial action task force MBR and how that will fit in with this. And you, you flagged it earlier or foreshadowed that the the kind of gaps that might be brought up and this is one that sounds like most nations and to some regard might be grappling with. But do you have any kind of hopeful insights into opportunities here? Or is this just one of those things we're still working out from an enforcement side? Speaker 4 I think, I think there's lots of opportunities. I mean, so an interesting variant on this is various ways to mule money. And one of the ways that that is done is an organized crime group in say, the United Kingdom will take advantage of the of students from China that are studying in Britain and they'll go after that diaspora. They won't ask them to launder money. What they will do is they will meet up with the student and say, hey, you're from this village, so am I. Even if they're not, they'll say that and they say, look, I got a buddy, He works downtown in Manchester. Here he's, he's underground in the kitchen, he's washing dishes. He just needs to get a little bit of money back to his family. Can you help him out? We'll give you, he'll give you the little pay packet. It'll be £1000. You take out £20 for yourself to, to go to the pub. And then can we, you just use your financial rail to send money back to your hometown and it'll get there. And then you scale that network up. Oh man, all of a sudden you've got a fantastic cash collection network. And the Brits have been very good at getting on top of some of these. And they're hard because they're not. Even though the ultimate value is big, the individual transactions are relatively small. And what they've done though, is they've launched a bit of a public relations campaign saying if you see a job ad that says no skills needed, earn this much money a week, all we need is your bank account, then you ought to know it's not just a scam, it's a crime. And you're probably a participant, a participant in a money laundering adventure. So those kinds of things, I think where we can educate people and shut those kinds of modalities down, it's cat and mouse. It's always going to happen. But I think that's something that I see as a positive possibility. Speaker 3 And such a good reminder that no matter how complex the economic system, the financial systems get, how globalized we become. I mean, you've brought us back a couple of times to the basics, right, to specialists doing specialist work and to communities, understanding the risks and challenges and being part of the solution. I mean, that is, I think, a wonderful message, as well as great anecdotes about how or what happens when we don't heed that message. FATF Evaluation, AML System Flaws, and Ethical Compliance I want to talk forever, but we're going to restrict it to two more questions. One of them is going to be to loop back to Canada's interaction with the Financial Action Task Force. As we know, mutual evaluation highly anticipated Australia in a similar boat. What are you predicting as some of the greatest risk areas of vulnerabilities for Canada in the context of the FATF regime? Speaker 4 Yeah, so, so, so the Fat F evaluators were on site in the fall of last year in Canada. I think we're relatively early in in the process and I know a lot of people that were at the tables. I wasn't personally at any of the tables, but I know a lot of people that were at it was an immense amount of work. They really do dive deep. It's hard to know what they'll say, but my, my sense is what they'll say about Canada is sort of two things. They will say for the most part, we have the right laws on the books. We could be better, but we have the the one exception to that are lawyers. They are exempt from our anti money laundering regime. They do not report up to the financial Intelligence Unit, which in Canada is FINTRAC, the equivalent of AUSTRAC. And that's a problem, but it's a problem that's hard for us to solve because it's a result of a Supreme Court of Canada decision that said that's an unconstitutional infringement on solicitor client privilege. So it's hard to know what will happen with that. I think a lot of the fat if evaluation will look at effectiveness though not what's on the books, but how are you using it. And I think that's where we'll see most of the commentary about Canada. I think you know, we don't have national coverage for civil forfeiture that'll be recommended. We only have four of the 10 current jurisdictions that have UW OS that'll be. So I think we'll see those kinds of recommendations and really improvement of the bandwidth of the specialist because this is, it's not rocket science necessarily. I mean, if I can figure it out, some other people can too. But it's, it does require specialized understandings of what dynamics are at play because people think of money laundering, they think instantly of cash and that's a big mistake. It's all about value. The, the example I gave you with the, the underground banking system, no cash ever leaves a border, but the value moves across four different borders. And that's exactly what they're trying to accomplish. And so you need to have some understanding of how that how those values work in order to get on top of the issue. Speaker 3 I mean, it wasn't the take out I was expecting from that. But that point I want to really emphasize your point of not about cash, it's about value. I think that's super important and subtle. Like you said, maybe it's not rocket science, but sometimes it's those really obvious subtleties that are missed and it's probably important for all of us to keep in mind when we're working in this space. Before I let you go, what do you see as the biggest challenges for law enforcement and effectiveness of our AML regimes globally and also in Canada in particular? What do you see as kind of the biggest challenges and maybe also, if we can try and be optimistic, the next evolution in asset recovery and AML law enforcement strategies moving forward? Speaker 4 Yeah. So I think, I think the challenge part of the challenge is the volume. So there was, there's a, was an encrypt encrypted phone system called Encro Chat. And there were several 1000 users of this mostly in Europe and they thought they could talk in real time or text in real time without ever being detected by law enforcement. In fact the the servers at the back end were very poor and they they were intercepted and there were lots of arrests and stuff, particularly in Europe. But I know one of the members of Garda in Ireland said the volumes were dizzying. He said you just simply couldn't track them and chart them. We're used to doing those charts, the I2 charts and so on and so forth to see how everything connects. He said there was just way too much happening. And what he said, the number one sort of modality that they were seeing was informal value transfer systems. Someone would would put cash with a broker in Dublin. Two days later they'd fly to Dubai. And what they would do is take a €5 note that has the same serial number, neither side RIP it in half. And so when they presented that half of the €5 note to the broker in Dubai, they got the cash out. So the volume of this activity I think is always going to be a challenge. In terms of our AML system, One of the things that worries me about the Canadian AML system is that the way that we're regulating right now is we're we're pushing financial institutions and other intermediaries into kind of a ticking the box process. They're looking at what they have to do so that they don't have a regulatory consequence to the. So they'll file and they'll file and they'll file. They file protectively, especially on suspicious transaction reports and that puts a lot of noise into the system. And they're not spending the time to explain really why it is suspicious. They're kind of downloading that role into the financial intelligence unit. And it's it's a volume problem. It's also a capacity problem. And I, if I want to be hopeful about the future, I think that we need to rethink Amla little bit so that there's sort of an ethical framework about keeping malign business out of your institution, regardless of what your regulatory consequences are and about being thoughtful about why you're actually filing. And there's a bandwidth problem. And the biggest problem in some institutions is that the compliance department is an expense. It's a drag on profit and there's a fight with the people that are actually making profit. And you saw that in things like Crown Casino in in in Australia where you saw what happened when one gets outweighed by the other, profit gets outweighed by compliance, you get a disaster. And I think if people are more mindful about that and the end game and the long game, I think we'll be better off. Speaker 3 Yeah. I mean, fantastic points, Jeffrey. I completely agree, which always makes it easy. But I do think that that point about volume in terms of transactions, but also in terms of the ways that some of our legislative frameworks are creating unintended side effects like this idea of well, we need to comply with our reporting obligations. So we're going to comply, but losing sight of the purpose or the ethics or the intention and the pre steps behind this a challenge, but also, as you know, an opportunity. So I always like to leave our listeners so they can sleep at night, even if the dreams will be very exciting. And I could have talked to you for three hours about some of those anecdotes that we've just sprinkled in there. Jeffrey Simser's Final Thoughts and Podcast Outro So hopefully we get another opportunity, but I will let you go. I really appreciate the time. Anything you'd like to share in in conclusion with our audience, please take it away. Speaker 4 Yeah, I know. Thank you. First up, thank you for having me. I think the one thing I would observe is that I've learned a lot from Australia, New Zealand, Ireland, England, Europe and and I would encourage readers that are interested in the area there. There's some things you can learn from Canada as well. I think the more that we share and have a like mind, the better off we all are. Speaker 3 Thank you so much, Jeff. We appreciate that and wholeheartedly agree once again. Speaker 1 The Financial Integrity Hubs research is at the cutting edge of understanding and tackling illicit finance threats, providing the international community with essential knowledge, tools and insights to make a real impact. If you want to stay ahead in the world of financial integrity, make sure to follow us on LinkedIn and on Spotify. We're always sharing the latest updates and events, breaking news and research insights. Join us and become part of a global community committed to fighting financial crime and protecting our economies and societies from illicit finance threats. A huge thank you to Doctor Doran Goldbach for his academic leadership, to Creative Beast for the editing, to Arctic Intelligence for their support in bringing this podcast to life, to Doctor Craig Cameron and to Doctor Hannah Harris for hosting. Thank you for listening. We will return with further conversations shaping the future of financial integrity.