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The Institute of Canadian Bankers/The Trust Institute's Submission in Response to Finance Canada's Enhancing Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime consultation:

The Institute of Canadian Bankers
The Trust Institute

Marie Muldowney
Executive Director

Tel (514) 840-8700 Fax (514) 282-6450

September 27, 2005

Ms. Diane Lafleur
Director, Financial Sector Division
Department of Finance
140 O'Connor Street
Ottawa, Ontario KIA 0G5

Ms. Lafleur,

The Institute of Canadian Bankers welcomes the opportunity to comment on the consultation paper "Enhancing Canada's Anti-Money Laundering and Anti-Terrorist Financing Regime".

As a provider of educational activities for the financial services sector, we commend the initiatives outlined in the consultation paper to strengthen Canada's AML/ATF framework. In particular we support the steps that are recommended to create a new AML/ATF advisory committee. In our own business processes and learning solution development we endeavor to ensure that we meet the needs of the financial services sector through the involvement of advisory committees. We therefore believe strongly that cooperation between all levels of government regulators and financial sector participants will be critical to the success of Canada's initiative to combat money laundering and terrorist financing.

As leading developers of AML/ATF compliance learning solutions we offer our expertise in working with committees to create compliance learning solutions and would be pleased to be considered for inclusion on the advisory committee. Your response to this offer would be appreciated. For the purposes of this committee my preferred language for further communication is English, however, I can communicate in French as well.

Please feel free to post this comment on the Department of Finance Canada website. Details on my contact information are included on the above letterhead.


Marie Muldowney

1002 Sherbrooke St. West
Suite 1000
Montreal, Quebec H3A 3M5
4 King Street West
Suite 1500
Toronto, Ontario M5H 1B6
510-5th Street S. W.
Suite 900
Calgary, Alberta T2P 3S2