Horizontal Initiative

Name of Horizontal Initiative: Integrated Market Enforcement Teams (IMET) Program

Name of lead department: Public Safety Canada

Lead department program activity: Countering Crime

Start date: 2003-04

End date:2012-13 and Ongoing

Total federal funding allocation (start to end date):$302,599,000 from 2003-04 through 2012-13 and $36,800,000 ongoing*

*All numbers include the employee benefits plans (EBP) and PWGSC accommodation costs.

Initiative description (including funding agreement): The objective of the IMET program is to effectively enforce the law against serious criminal capital market fraud offences in Canada. To achieve this objective, IMET is mandated to investigate serious Criminal Code capital market fraud offences that are of regional or national significance and threaten investor confidence or economic stability in Canada.

Shared outcome: Improved Canadian and international investor confidence in the integrity of Canada’s capital markets.

Governance structure: The IMET Executive Council is composed of senior officials from the Royal Canadian Mounted Police (co-chair), Department of Finance (co-chair), the Office of the Director of Public Prosecutions, Department of Justice and Public Safety Canada who provide strategic oversight for the IMET program.

Performance Highlights: All necessary foundational work was completed to establish a Ministerial Expert Panel that will provide advice and recommendations on practices to enhance the strategic orientation and performance of the IMET program. The RCMP has undertaken a greater number of intelligence led, proactive investigative initiatives within each investigative IMET unit.

Integrated Market Enforcement Teams (IMET) Program
Federal Partners PAA Programs Contributing activities/
programs		 Total Allocation (from start date
to end date)
($ dollars)		 2012-13 ($ dollars)
Planned spending Actual spending Expected results Contributing activity/
program results (using specific indicators)
Public Safety Canada Countering Crime IMET 2003-04 to FY 2007-08: $1,125,000 FY 2008-09 to FY 2012-13: $1,703,290 Ongoing: $340,658 $340,658 $248,106 Fulfillment of Public Safety Canada's IMET program management responsibilities, including coordination, reporting, evaluations, policy development and research Public Safety Canada coordinated developmental work to establish a panel of experts to provide advice and recommendations on practices to enhance the strategic orientation and performance of the IMET program.
Public Safety Canada fully participated in IMET Executive Council and the IMET working group.
Internal Services IMET FY 2008-09 to FY 2012-13: $590,660 Ongoing: $68,132 $68,132 $68,132 Provision of program support Supported the work of the program by providing key corporate services.
Royal Canadian Mounted Police
(RCMP)		 Federal and International Operations IMET FY 2003-04 to FY 2007-08: $74,000,000 FY 2008-09 to FY 2012-13: $154,584,010 Ongoing: $30,968,817 $30,968,817 $23,695,032 RCMP's IMET will strive to be intelligence-led and fulfill its mandate to the fullest extent possible based on funding received. It will perform its prevention and investigation responsibilities, including the operation of the securities intelligence units (SIUs), investigative teams, headquarters operational support, and program management. The IMET Program has maintained its' focus on proactive policing by undertaking a greater number of intelligence led, proactive investigative initiatives within each investigative unit. In furtherance of the IMET Program intelligence model development, the Capital Market Integrated Intelligence Assessment Report had been completed. The SIU's “Meet the Street” initiative has continued to develop resulting in over 50 separate IMET presentations to compliance professionals from investment dealers and pension funds as well as to University MBA faculty /students and the legal community. IMET personnel have hosted “Industry Roundtable” meetings with senior pension fund compliance officers and investment dealers in Toronto.
Office of the Director of Public Prosecutions (ODPP) Regulatory offences and economic crime prosecution program IMET FY 2003-04 to FY 2007-08: $3,750,000 1 FY 2008-09 to FY 2012-13: $29,266,685 Ongoing: $4,353,337 2   $5,853,337 $2,263,012 Provision of pre-charge legal advice and litigation support, as well as prosecution of serious capital market fraud offences under the Criminal Code in response to the workload generated by the IMETs. Over the course of 2012-13, the ODPP dedicated a total of 12,061 hours to IMET related activities, including the provision of legal advice and litigation support, prosecution services as well as management and administrative support.
ODPP counsel participated in two significant IMET - related prosecutions – one in Montreal and one in Halifax.
Department of Justice (DOJ) Justice, Policies, Laws and Programs IMET FY 2003-04 to FY 2007-08: $26,674,000 1 FY 2008-09 to 2012-13: $9,075,780 3 Ongoing: $705,156 3 $2,405,156 3 $120,525 Market fraud cases are effectively prosecuted in order to maintain confidence in Canadian capital markets. The object of the IMETs Reserve Fund is to assist Provincial Attorneys General by defraying certain prosecution related costs arising from IMET investigations. In 2012-13, one application for funding was received and approved.
Services to Government IMET FY 2008-09 to 2012-13:
$844,110 Ongoing: $168,822		 $168,822 $171,570 The International Assistance Group (IAG) provides legal advice on international assistance requests and coordinates all IMET requests to and from foreign countries. Once a request for mutual legal assistance (MLA) has been executed, it is the responsibility of the RCMP, not the IAG, to monitor the outcome of the relevant investigation or prosecution for which the evidence was gathered. The International Assistance Group (IAG) provided legal advice on international assistance requests and coordinated all IMET requests to and from foreign countries, including:
  • Assisted IMET personnel in the preparation of all outgoing mutual legal assistance (MLA) requests.
  • Liaised regularly with IMET headquarters and IMET regional offices.
  • Provided legal advice and assistance in the area of MLA to IMET headquarters and IMET regional offices (Montreal, Toronto, Calgary and Vancouver) with respect to current and potential MLA requests.
  • Reviewed and approved IMET MLA requests.
  • Transmitted IMET's outgoing MLA requests to the central authority of the requested state.
  • Followed-up with IMET personnel and foreign central authorities to ensure that all IMET MLA requests were executed in accordance with the treaty and the terms of the request.
  • Assisted in the gathering of evidence of all 17 outgoing MLA original and supplemental requests in relation to IMET investigations.
  • Reviewed all incoming IMET MLA requests to ensure that they met the relevant treaty and Canadian legal requirements.
  • Prepared monthly IMET MLA status reports that were provided to IMET headquarters and IMET regional offices.
  • Met quarterly with IMET headquarters and ODPP and provided legal advice in the areas of current and potential MLA requests.
Internal Services IMET FY 2008-09 to 2012-13:
$113,425 Ongoing: $22,685		 $22,685 $22,685 Support the needs or the program through related activities and resources. N/A
Finance Canada Economic and Fiscal Policy Framework                   IMET                     FY 2008-09 to 2012-13:
$872,040 Ongoing: $172,393		 $172,393 $172,393 As Co-Chair of the IMET Executive Council and the Interdepartmental Working Group, Finance Canada is to provide strategic direction to the IMET program that reflects the Government of Canada's broader capital markets agenda. Finance Canada is to provide leadership in engaging external stakeholders in efforts to enhance program performance, including opportunities to strengthen the continuum of enforcement. Through its role as Co-Chair of the IMET Executive Council and Working Group, Finance Canada provided leadership and strategic direction to the IMET program.
Total $302,599,000**
Ongoing: 36,800,000		 $40,000,000 $26,758,669  

**The total allocation indicated in this Departmental Performance Report (DPR) differs from the figures presented in the 2012-13 Report on Plans and Priorities (RPP). The total allocation amounts in the 2012-13 DPR are the correct figures and are to be considered official.

Comments on Variances:

Public Safety Canada:
Remaining funds were reallocated towards departmental priorities in order to meet key deliverables.
Royal Canadian Mounted Police:
As noted in Chapter 5 of the June 2011 Status Report of the Auditor General of Canada, the RCMP has had to reallocate funding internally from all programs in order to meet the increased demands for National Policing Services. Furthermore, various Federal and Protective policing priorities have created additional requirements to reallocate funding and resources.
Office of the Director of Public Prosecutions:
The decrease of $3.6M from planned spending to actual spending is due to the fact that the ODPP did not make use of the $1.5M contingency reserve and had participated in only two significant prosecutions. These prosecutions did not require the use of all the funding that had originally been allocated.
Justice Canada:
Justice, Policies, Laws and Programs – In 2012-13, one application for funding was received and approved. As no other applications were received, the remainder of the funding earmarked for the IMETs Reserve Fund lapsed.
Finance:
N/A  
Results achieved by non-federal partners (if applicable): N/A
Contact information:
Name: Trevor Bhupsingh
Title: Director General, Law Enforcement and Border Strategies, Public Safety Canada
Telephone: (613) 991-4281
Email: trevor.bhupsingh@ps-sp.gc.ca

1 Prior to the establishment of the Office of the Director of Public Prosecutions (ODPP) in 2006, funding for this program activity was allocated to Justice Canada's Federal Prosecutions Service. The amount shown does not include a transfer of $3.75M from Justice Canada to ODPP for FY 2007-08 following the creation of this organization.

2 The $1.5M decrease in ongoing funding is due to a strategic review decision effective in 2013-14 and ongoing.

3 The decrease in Total Allocation FY 2008-09 to 2012-13 and ongoing funding is due to a strategic review decision effective in 2012-13 and ongoing. The strategic review decision was not applicable at the time of the preparation of the 2012-13 Report on Plans and Priorities (RPP).

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