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Horizontal Initiatives




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

Name of Lead Department(s): Public Safety Canada

Lead Department Program Activity: Law Enforcement

Start Date: 2003-04

End Date: Ongoing

Total Federal Funding Allocation (from start date to end date): $304,299,000 from 2003-04 through 2012-13 and $40,000,000 per year ongoing (includes EBP and PWGSC accommodation costs).

Description of the Horizontal Initiative (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(s): Improved Canadian and international investor confidence in the integrity of Canada's capital markets.

Governance Structure(s): 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: A full evaluation of the Integrated Market Enforcement Team (IMET) program was completed in 2010. An action plan was developed to address the recommendations and work continues on its implementation. In addition, the RCMP has undertaken an organizational change to align with the recommendations in the Le Pan Report.

Horizontal Initiative: Integrated Market Enforcement Teams (IMET) Program
Federal Partners Federal Partner Program Activity Names of Programs for Federal Partners Total Allocation (from Start to End Date) 2010-11 ($ millions)
Planned Spending Actual Spending Expected Results Results Achieved
Public Safety Canada Law Enforcement IMET FY 2008-13: $1,703,290 (Ongoing: $340,658) $340,658 $335,616 Fulfillment of Public Safety Canada's IMET program management responsibilities, including coordinating reporting, evaluations, policy development and research

PS completed a full program evaluation in accordance with Treasury Board Secretariat guidelines.

PS coordinated the commission of a study on the vulnerabilities of the Canadian Securities markets to infiltration by organized crime.

PS collaborated in the development of a Joint Management Response and Action Plan to implement the outstanding Le Pan Report and the Benchmarking Study recommendations.

PS fully participated in IMET Executive Council and the IMET working group.

Internal Services   FY 2008-09 to 2012-13: $590,660 (Ongoing: $68,132) $68,132 $68,132 Provision of program support Internal services operating expenditures incurred to support the activities of the program through the provision of key corporate services.
Royal Canadian Mounted Police Federal and International Operations IMET FY 2008-09 to 2012-13: $154,584,010 (Ongoing: $30,968,817) $30,968,817 $25,116,584 Fulfillment of the RCMP's IMET prevention and investigation responsibilities, including the operation of the securities intelligence units (SIUs), investigative teams, headquarters operational support, and program management.

Several RCMP Integrated Market Enforcement Team (IMET) program's project status investigations worked their way through the final stages of the court process during the 2010-11 fiscal year. As well, charges were laid in two investigations. In December 2010, the RCMP charged an individual in Vancouver with nine fraud and related charges in a case allegedly involving approximately $150M; while in February 2011, the RCMP charged 11 individuals in Montreal with fraud and fraudulent manipulation of stock exchange transactions, valued at approximately $3M.

During the fiscal year, an organizational change took place within RCMP's Federal Policing directorate. The Assistant Commissioner of Financial Crime (AC/FC) now reports directly to the Deputy Director, Federal Policing. This reorganization is in line with recommendations made by Nick Le Pan in his 2007 "Report to the Commissioner: Enhancing Integrated Market Enforcement Teams, Achieving Results in Fighting Capital Markets Crime".

In May 2010, the report of a full evaluation of the Integrated Market Enforcement Team (IMET) program was submitted to the Treasury Board Secretariat, and made available publicly. Coordinated by the Department of Public Safety, this evaluation was generally supportive of the IMET program. The RCMP prepared an action plan to address the recommendations and work continues on implementing this plan.

Office of the Director of Public Prosecutions (ODPP) Regulatory offences and economic crime prosecution program IMET FY 2008-09 to 2012-13: $29,266,685 (Ongoing: $5,853,337) $5,853,337 $4,080,261 Provision of pre-charged legal advice and litigation support, as well as prosecution of fraud offences under the Criminal Code in response to the workload generated by the IMETs.

Over the course of 2010-11, the ODPP dedicated a total of 23,660 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 acted as co-counsel in two IMET prosecutions. Near the end of 2010-11, the ODPP took carriage of three other IMET prosecutions that are still before the courts.

As well, the IMET reserve fund was accessed to retain an agent to prosecute a case, with staff counsel acting as co-counsel.

Department of Justice (DOJ)[1] Justice, Policies, Laws and Programs IMET FY 2008-09 to 2012-13: $10,775,780 (Ongoing: $2,405,156) $2,405,156 $558,432 Provincial Attorney Generals of IMET participating provinces are aware of and able to access the IMET Reserve Fund.

Two applications were received and all inquiries about the IMET Reserve Fund were responded to in a timely manner.

Two agreements were signed to support eligible expenditures

Service to Government IMET FY 2008-09to 2012-13: $844,110 (Ongoing: $168,822) $168,822 $169,483 Provision of legal advice on international assistance requests and coordination of all IMET requests to and from foreign countries.[2]

Legal advice was provided on international assistance requests and all IMET requests were coordinated to and from foreign countries.

DOJ assisted IMET personnel in the preparation of all outgoing MLA requests.

DOJ liaised regularly with IMET headquarters and IMET regional offices.

DOJ 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.

DOJ reviewed and approved IMET MLA requests.

DOJ transmitted IMET's outgoing MLA requests to the central authority of the requested state.

DOJ 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.

DOJ assisted in the gathering of evidence of all outgoing MLA requests in relation to eight IMET investigations.

DOJ reviewed all incoming IMET MLA requests to ensure that they met the relevant treaty and Canadian legal requirements.

DOJ prepared monthly IMET MLA status reports that were provided to IMET headquarters and IMET regional offices.

DOJ met quarterly with IMET headquarters and PPSC and provided legal advice in the areas of current and potential MLA requests.

DOJ provided MLA training to IMET personnel.

Internal Services   FY 2008-09 to 2012-13: $113,425 (Ongoing: $22,685) $22,685 $20,808 Provision of program support Internal services operating expenditures incurred to support the activities of the program through the provision of key corporate services.
Finance Canada Economic and Fiscal Policy Framework IMET FY 2008-09 to 2012-13: $872,040 (Ongoing: $172,393) $172,393 $172,393

Provision of strategic direction to the IMET program that reflects the Government of Canada's broader capital markets agenda.

Provision of leadership in engaging external stakeholders in efforts to enhance program performance, including opportunities to strengthen the continuum of enforcement.

Finance Canada provided oversight and strategic direction to the IMET program.
Total $304,299,000 $40,000,000 $30,352,226    

Comments on Variances:

Public Safety Canada: Variance between planned and actual spending is attributed to staffing changes.

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. Consequently, the IMET program was subject to an internal reallocation resulting in $3.9M being directed toward RCMP pressures.

Justice Canada: Variance between planned and actual spending is attributed to the limited number of applications submitted by the Provinces to support eligible expenditures under the Reserve Fund.

Results to be achieved by non-federal partners (if applicable): N/A


[1] All amounts include PWGSC accommodation costs totaling $27K for 2010-11 planned and actual spending. The Department of Justice received for FY 2003-04 to 2007-08 a total funding of $26.67M (including accommodation) and this amount takes into account a transfer of $3.75M to ODPP for the FY 2007-08 following the creation of this organization.

[2] Once a request for mutual legal assistance has been executed, it is the responsibility of the RCMP, not the Department of Justice, to monitor the outcome of the relevant investigation or prosecution for which the evidence was gathered.