Bruce McCulloch and Joe McGrade join Counterfactual host Julia Potter of Blake, Cassels & Graydon LLP to provide US and Canadian perspectives on the key highlights and additional insights from the panel discussion at the 2025 Annual Criminal Matters Committee Town Hall hosted by the CBA Criminal Matters Committee.
In this episode of the Counterfactual Podcast, we hear from Bruce McCulloch from Freshfields Bruckhaus Deringer and Joe McGrade from Blake, Cassels & Graydon LLP provide US and Canadian perspectives on the key highlights and additional insights from the panel discussion at the 2025 Annual Criminal Matters Committee Town Hall hosted by the CBA Criminal Matters Committee. They discuss emerging trends in criminal enforcement, including declining use of leniency programs, the growing scrutiny of ESG and DEI-related collaborations, and cross-border coordination amid shifting political landscapes.
00:30
Julia Potter
Hello and welcome to Counterfactual, the official podcast of the Canadian Bar Association’s Competition Law and Foreign Investment Review section. My name is Julia Potter. I am a partner in the Competition, Antitrust & Foreign Investment group at Blake, Cassels & Graydon, and I will be your host.
00:47
Julia Potter
This episode continues the conversation from this year’s Annual Criminal Matters Committee Town Hall hosted by the CBA Criminal Matters Committee that took place on February 26.
00:56
Julia Potter
Today I will interview Bruce McCulloch from Freshfields and Joe McGrade from Blakes, providing the key messages from the panel discussion and some additional discussion building on what we heard at the session.
01:08
Julia Potter
Whether you attended the session or not, this episode is for you. As a brief note, this episode was recorded in late February and so there may be content that is now slightly out of date.
01:19
Julia Potter
And moving on to a quick introduction of our guests.
Bruce McCulloch is a partner in the antitrust, competition, and trade practice at Freshfields, based in their Washington, DC office. Bruce has significant experience in merger control, conducting investigations, antitrust counseling, litigation and representation before the Department of Justice and the Federal Trade Commission.
01:41
Julia Potter
He represents clients in a wide range of industries, including automotive, consumer products, defence, healthcare, manufacturing, mining, natural gas gathering and processing, oil and gas exploration and distribution and wholesale drug distribution.
01:56
Julia Potter
Our other guest today, Joe McGrade, is a member of the Competition, Antitrust & Foreign Investment group at Blakes.
02:03
Julia Potter
His practice focuses on all aspects of competition law and advocacy, including contested merger litigation, class actions, merger review, price fixing and cartel investigations, abuse of dominance, joint ventures and strategic alliance, and regulatory compliance.
02:18
Julia Potter
He also advises on foreign investment merger review under the Investment Canada Act. Joe has appeared before the Federal Court of Appeal, the Competition Tribunal, and the Ontario Superior Court.
02:31
Julia Potter
Great. Well, thank you both for joining us today. I think we'll just jump right into the questions. There were a number of interesting topics that were discussed at the Town Hall session, and you touched on the traditional collaboration between the Competition Bureau and PPSC in Canada and the DOJ in the U.S., in respect of cross-border criminal enforcement matters.
02:52
Julia Potter
Is this relationship expected to change either under the new Trump administration generally or as a result of the potential tariffs? Bruce, why don't we start with you?
03:02
Bruce McCulloch
Sure. The Canadian and US antitrust authorities have had a long history of cooperation. I don't expect that to change, especially with regard to criminal cartel enforcement. Both countries have a strong interest in prohibiting anticompetitive conduct.
03:19
Bruce McCulloch
And, you know, as I've said in the past, everybody hates cartels. I can't imagine that tariffs or other geopolitical forces will have an impact on cooperation in this area.
03:32
Bruce McCulloch
As we discussed in the Town Hall, tariffs can lead to market distortions in the short term, at least. And both U.S. and Canadian companies will need to react to potential changes in market conditions as a result of tariffs, but going both ways.
03:50
Bruce McCulloch
And antitrust considerations will need to be considered as, you know, those markets actually change as a result of the tariffs.
03:59
Julia Potter
Joe, how about you? What about from your perspective?
04:01
Joe McGrade
Yeah, I don't expect we'll see much change in the Bureau and PPSC's criminal enforcement as a result of the tariffs. You know, crime remains crime. Where we might see change is more in the foreign investment context, where, you know, you have American investors looking to invest into Canada. Trade relationships are more fraught than they have historically been, you know, instead of saying that American investors are 99% sure to make it through without much trouble on an ICA perspective. Maybe that's now 97% or 96%.
04:38
Joe McGrade
Or maybe in the context of a net benefit review, you might see the government looking for some more stringent undertakings than they would have, or looking even in the context of ordinary undertakings, to make a more public statement about the undertakings, whereas previously it would have flown under the radar. The ICA is an inherently political process.
05:00
Joe McGrade
And so that's the one where I'd keep an eye out for more responses to these political developments with respect to the tariffs.
05:06
Bruce McCulloch
Yeah, and we have that, obviously, regime in the U.S., CFIUS, and Canadian investors have historically been a rubber stamp approval. In fact, we don't even really pay much attention to it.
05:20
Bruce McCulloch
I'm not a CFIUS lawyer. I'll qualify that. But again, I don't think that's going to have an impact on CFIUS review. But, you know, we'll see. It's a fair point.
05:31
Julia Potter
Yeah, it's an interesting time with certainly some changes to be seen, so we'll have to all watch out for those. And Bruce, at the Town Hall, you talked about certain sectors or businesses that you expect to receive more of a focus from the U.S. agencies under the new Trump administration. Would you be able to speak to that a little bit here?
05:49
Bruce McCulloch
Sure, it's early but we've seen the Trump administration enforcers begin to outline their priorities on the antitrust front. The new chair of the FTC, Andrew Ferguson, is in place, and other enforcers, including the incoming Assistant Attorney General for Antitrust, Gail Slater, has gone through her confirmation hearing and likely will be in place soon. I'm hearing as early as next week.
06:16
Bruce McCulloch
Early indications suggest that the Trump enforcers will continue with vigorous antitrust enforcement. That's what they've said. And the scrutiny that is currently ongoing in the tech sector is likely to continue.
06:32
Bruce McCulloch
Another area that is a focus is pharma. That is something that I think you'll see, you know, in enforcement and regulation across agencies in the U.S., not just antitrust.
06:49
Bruce McCulloch
In addition, anticompetitive conduct impacting labour will continue to be a priority. And the FTC has already announced a task force that will look into practices that adversely impact labour in the U.S.
07:05
Bruce McCulloch
The focus on labour issues began actually in the first Trump administration and continued vigorously with the Biden administration. That clearly will continue.
07:16
Bruce McCulloch
And lastly, you know, the Trump administration has announced a focus on collusion, in relation to ESG and DEI efforts, which was not a focus of the Biden administration. We'll talk about that a little more.
07:30
Bruce McCulloch
Other areas where I think you might see maybe less scrutiny are with private equity, which under the Biden administration was a clear target. I think that might ease off a little bit.
07:45
Bruce McCulloch
And areas such as energy, which are a focus of the administration as a whole, I think, again, might receive less scrutiny than under the prior administration, certainly for fossil fuels as opposed to renewables.
08:01
Julia Potter
And Joe, did you have anything to add there?
08:03
Joe McGrade
Not on the US areas of focus, I'll defer to Bruce there. But in terms of what the Bureau is looking at, I think we remain in a very consumer-focused enforcement regime, perhaps as it should always be. But the cost-of-living crisis, while maybe a little bit behind us, is still very top of mind, so things that relate to people's everyday lives and the expenditures that they make, like groceries, are still very top of mind.
08:32
Joe McGrade
Rent is very top of mind right now, including the recent investigation into potential AI pricing and the use of that to increase rents. I think the Bureau is going to be looking there, firstly, in terms of consumers and what hits their wallets and what is very big in the public mind.
08:48
Joe McGrade
In terms of, not so much sectors, but enforcement priorities, I think given the amendments we've had and the new powers that the Bureau has, they're going to be looking for test cases to sort of test out the new tools that they have under the Act.
09:02
Joe McGrade
In the criminal context, the biggest one there is potential criminal wage fixing or no coach agreements. Bruce said that's going to be a priority in the States. I imagine that will continue to be a priority in Canada.
09:15
Joe McGrade
We haven't yet seen much enforcement under that provision. So there still remains some sort of uncertainty as to what kinds of cases the Bureau will be looking for, how they're going to calculate fines, and how they're going to go about those kinds of investigations.
09:31
Joe McGrade
I think that's something that we should keep an eye on. Although one thing that did come out of the Town Hall was it doesn't seem like there's much activity there from the Bureau yet. So that might be something they're just taking their time to build a good test case on, or maybe it's not something that's a high priority for them right now. But I expect, given that it's new and untested, they're looking to build some law there.
09:52
Julia Potter
Yeah, that all sounds right. So during the Town Hall event, we heard about how the use of immunity and leniency programs has been declining. And so, Joe, turning to you, how do you foresee the immunity and leniency program being used going forward? And what would you say is the main challenge facing these programs that might be leading or at least contributing to their lessened use over time?
10:14
Joe McGrade
The discussion at the CBA panel, I thought it did a good job of pitting the carrot against the stick, right? And it's sort of an imbalance between the two sides.
10:24
Joe McGrade
The carrot on the one side for immunity, you know, you do have some real carrot there where you and your executives are immune from criminal prosecution and fines.
10:34
Joe McGrade
But, you know, you still have the follow-on class action litigation, which is oftentimes significantly higher than the fine risk that you would have. Sometimes, you know, 10 times higher. It's just as significant, it's like an order of magnitude larger. Although potentially with the new fines that will change, but at least historically that's been the case.
10:54
Joe McGrade
And you also have other impacts like potential debarment from government contracts, if that's a big part of your program, particularly if you're a leniency applicant and you do actually have to put in a criminal plea, that's something that takes a big cost.
11:08
Joe McGrade
And then there's also just the media attention, right? If you come out and the Bureau makes a statement or you enter a guilty plea, you're looking at brand impact, you're looking at impact on your business in the public eye.
11:20
Joe McGrade
And, you know, that's the cost and the benefit to offset that cost is, especially for leniency, maybe not that high. So you have immunity from criminal prosecution, but you still have to pay what could be a significant fine and enter a guilty plea, which is not something that most businesses want.
11:40
Joe McGrade
So that's the kind of carrot side. And if you go over to the stick, what happens if you don't self-report or cooperate? Well, you might face a potential Bureau investigation or prosecution.
11:51
Joe McGrade
But as we talked about at the panel, there's not a very strong track record of the Bureau successfully with the PPSC bringing successful criminal prosecutions. So the stick might not be sufficiently hefty to offset the cost of self-reporting. So the calculus for businesses, I think, tends to skew towards not self-reporting, just given the way the regime is set up.
12:19
Joe McGrade
And I think that's kind of where we are now and why we've seen the decrease in leniency and immunity applications in recent years, at least in Canada.
12:26
Julia Potter
Yeah, and Bruce, what can we learn from the US in terms of how to make community leading seat programs more attractive? Or are you facing similar challenges there as well?
12:35
Bruce McCulloch
Yeah, it's more the latter. You know I'm not sure what can be learned from the US, but, you know, as Joe indicated, the attractiveness of leniency has declined over the years. And the US, like many jurisdictions, has seen a decline in leniency applicants over the years, at least with regard to large multinational matters. We're just not seeing those in the last five to six years. And you know if anything, you talk about the US, leniency in the US offers a pretty big carrot, more so than in many other jurisdictions. In addition to fine relief, leniency has a private damages benefit under ACPERA, subjecting leniency holders to single damages in private litigation as opposed to treble damages.
13:29
Bruce McCulloch
And ordinarily, it also provides release from criminal prosecution of individuals at the company. And that can be a big carrot for especially senior executives who, without reporting, could face jail time. And it is the practice in the U.S. for at least, I mean, I think the standard is two people, the highest-ranking people involved in the collusion to go to jail.
13:57
Bruce McCulloch
But despite this, you know, the threat of private litigation, both inside and outside the US. It's not just the US, it's obviously Canada. It's been Canada for a while, but it's grown in Europe tremendously.
14:11
Bruce McCulloch
In addition, the need for leniency applications in multiple jurisdictions as well factors into it. And that often makes the decision difficult when, you know, as Joe says for Canada, it's true for other U.S. and other jurisdictions as well. These are not that easy to find.
14:31
Bruce McCulloch
You know, the actual conduct. And so it has been predicted and people were talking about it for years, during COVID and after, that leniency applications would rise sharply in the post-COVID period because of supply shortages and supply chain disruptions that there would have been more conversation and discussion and agreement that would take place during the COVID period.
14:57
Bruce McCulloch
Well, I mean, we've yet to see that. It could still be coming, but we have not seen it. And so in talking about cartel activity, the interesting phenomenon we've seen some in the U.S. is, you know, we all grew up, you know, talking about follow-on class actions.
15:18
Bruce McCulloch
Now we're seeing follow-on cartel enforcement, which is kind of a new thing where you will see investigations launched as a result of private actions being filed. And I've experienced that personally.
15:32
Bruce McCulloch
We're also seeing it with regard to European investigations. And so the plaintiff's lawyers clearly are finding it not as easy as it used to be, so we are seeing them dig for cases. And that can come from a variety of sources, whistleblowers, other private litigation.
15:53
Bruce McCulloch
And so it's sort of a new environment. And, you know, I don't know if leniency is fixable in this day and age.
16:00
Joe McGrade
Yeah, one thing I want to pick up from that Bruce is that you're talking about potential criminal enforcement for individuals and executives and how that might help the decision calculus to cooperate.
16:12
Joe McGrade
We don't really have that enforcement track record in Canada, and we have no significant jail time given out to executives. I think the closest we got was an ankle bracelet in one case, but to your point, if we're trying to get people to, if the Bureau or the PPSC's goal is to get people to cooperate,
16:30
Joe McGrade
you know, that might be an enforcement area where they could focus or also just work to limit the downsides. Right. Like, debarment is one that comes to mind as a pretty easy fix. The Bureau historically has given submissions that said, “hey look, if you're a cooperating party, you should not be debarred from federal government contracts, or the consequences should be limited”.
16:52
Joe McGrade
There's more discretion under the new federal integrity regime to make that happen. But I think that could be a good starting point to reduce the cost of cooperation if that's what we're looking to increase.
17:04
Julia Potter
Yeah, and well it does sound like any one jurisdiction's attempt to fix these programs is going to be one piece, but then the whole international puzzle makes it much more tricky.
17:12
Julia Potter
So even if Canada or the US, or whoever it is, is looking to update their regime, it's still going to have to be considered in an international context and what the costs are sort of globally for participating in these programs.
17:24
Julia Potter
So I guess we can move a bit. And Bruce, you already alluded to this today, but at the Town Hall, you talked about evolutions in antitrust criminal enforcement relating to ESG and DEI initiatives. And you had mentioned there were cases brought related to collusion among actors working to promote clean energy or other social interests. Can you talk a bit about that here for our listeners as well?
17:46
Bruce McCulloch
Sure. The Trump administration has made it clear through, you know, his or early executive orders and otherwise that it will target DEI and ESG efforts.
17:58
Bruce McCulloch
And one of the mechanisms to do that is through the antitrust laws. It's not the only mechanism, but it's certainly one that's available to the US enforcers. In particular, the FTC or DOJ, you know, they can target agreements among companies reached through public bodies or otherwise as potentially anticompetitive, either on the commercial front or on the labour front.
18:22
Bruce McCulloch
And we've already seen some action here in the U.S. There was a suit filed, I think it was late last year, Texas was the lead, but 11 total states, attorneys generals from red states are suing certain PE companies for collusion in relation to suppressing the output of coal.
18:42
Bruce McCulloch
And, you know, in essence, companies cannot collude to reach a desired outcome, even if that outcome is deemed to be for the collective good. You know, for example, in that case, reduce burning of coal.
18:57
Bruce McCulloch
You know, and that is creating some anxiety in the US. We'll see how it proceeds with the federal enforcement in the months ahead.
19:08
Bruce McCulloch
But it is already creating anxiety among multinational companies that face very different demands across jurisdictions, be it on DEI or ESG.
19:22
Bruce McCulloch
In certain areas, there are exemptions, for, you know, certainly for ESG measures, that are designed to reach certain goals that jurisdictions want, you know whether it's climate change or otherwise.
19:39
Bruce McCulloch
The U.S. does not have that exemption, so companies are going to have to deal with the fact that collective action, even if they feel that it's for the good, is not something that's going to be necessarily allowed in the U.S. under this administration.
19:56
Julia Potter
Joe, what's the Canadian perspective on that? I don't think that's somewhere we've gone yet, but…
20:01
Joe McGrade
No, it's a very different political environment in Canada versus the United States with respect to ESG and DEI. I don't believe that we're in the same kind of backlash or set of sort of political antagonism towards those policies. So I don't expect policing ESG or DEI agreements to be a big priority for the Bureau or the PPSC or the government.
20:27
Joe McGrade
So I think that we're less likely to see those kinds of investigations here. We don't have the full kind of exemptions that Bruce was talking about, but it is built into the act that companies who want to collaborate to protect the environment can seek a certificate from the Bureau that says that that's okay.
20:44
Joe McGrade
If they're able to show that the purpose of the agreement is to protect the environment and that it is not harmful to competition. It seems like Bruce, that last prong of the test, is it harmful to competition? The thinking about whether ESG is harmful to competition has changed in the States a little bit.
21:00
Joe McGrade
But look, it's a new measure in Canada. It was introduced in June 2024. I haven't personally dealt with it. I don't think that there have been a lot of environmental certificates, if any, that have been applied for.
21:11
Joe McGrade
Not a lot of people want to go to the Bureau and say, “hey, is this a cartel?” So, query the extent to which that will be used.
21:18
Joe McGrade
But I personally don't think that we'll see the same kind of focus on ESG or DEI enforcement from the Competition Bureau or PPSC in Canada, partly by virtue of our cartel provisions, which are a little more circumscribed, and partly, I think, more importantly, due to the different political feelings that exist north of the border here.
21:39
Bruce McCulloch
Yeah, I know. And it's obviously a change in the U.S. with this administration. But, you know, it's not necessarily new. You know, I've advised even under the Biden administration that, you know, when you have an ESG measure, there's often a winner and a loser. Right.
21:59
Bruce McCulloch
I mean, so on the energy front, the winners, lately in the US, have been renewables, and the losers have been coal, especially, but fossil fuels generally. My caution always to companies is yes, it may not be the administration that comes after you, but when there is a loser, there's always the threat of private litigation. And so it's certainly not a new risk from an antitrust perspective but now it's absolutely heightened in the U.S. when you've got the federal enforcers now obviously looking at all of these actions through a microscope.
22:38
Julia Potter
Yeah, it's a very interesting sort of new era for that in the US and we'll see what happens in Canada. Here we've been more focused on greenwashing, I'd say, than worrying about collusion in respect to these kinds of issues, but I guess we'll see how that develops here as well.
22:53
Julia Potter
And so just going back to the event itself, it was an interesting event with quite a bit of audience participation. I was interested if there were any questions or if there was any discussion from the audience that you found particularly interesting and might want to talk about here.
23:08
Julia Potter
And Jo, maybe I'll start with you on this one.
23:12
Joe McGrade
Yeah, it was a great event. Thank you to all of our attendees, and a double shout-out to those who are both panel attendees and podcast listeners. You're our favorite kind of people, so thank you.
23:22
Joe McGrade
For me, the thing that was most interesting, we got into a discussion about just how big the new AMPs are under the new provisions of the Competition Act.
23:34
Joe McGrade
So first of all, criminal provisions have now uncapped fines at the discretion of the court. It can be up to any number. Historically, though, those numbers have been, I don't want to say “fairly small”, but, you know, in the $50 million dollars range of the cap in terms of the biggest criminal fines that we've seen, often much lower.
23:53
Joe McGrade
Historically, there was a $25 million dollars cap per count, even lower going farther back. But now, even under the civil provisions, the AMPs have gotten significantly larger, particularly the AMPs that allow for a maximum of 3% of global turnover if you're not able to determine the benefit derived from the conduct.
24:14
Joe McGrade
And that number can be huge. For example, there's a Bureau Abuse of Dominance investigation currently happening with respect to Google. Google is contesting that. And as part of their contesting of the abuse claim, they're saying that the magnitude of that fine is unconstitutional just because of the sheer size of it.
24:35
Joe McGrade
And also the fact that it's a civil provision, right? Like there are protections that you have as someone who's facing a penal penalty, whether that be, you know, jail time or a fine that's of such a significant nature to render it into a penal kind of remedy.
24:51
Joe McGrade
And the Bureau doesn't really have those protections in place under the civil provisions, arguably, and it faces a much lower burden of proof than you would, right? It's just a civil provision, it's the balance of probabilities as opposed to beyond a reasonable doubt.
25:04
Joe McGrade
And so the question is, you know, to what extent should the Bureau be able to extract these potentially enormous fines, through the civil provisions, where historically you would bring claims under the criminal provisions and have the protections that go along with those. So that to me is a really interesting question to watch and keep an eye on. You know, you see where the Bureau is coming from, where they say, look, we have these civil tools, we can extract these significant AMPs, we have a lower burden of proof, we don't have the Stinchcombe disclosure obligations, you know, it's lot easier to go this way.
25:37
Joe McGrade
So understand why they might be looking that way. But, you know, query whether that's something that's permissible or whether that's something that we should guard against and push back on.
25:48
Julia Potter
Yeah, it's interesting. And Bruce, was there anything sort of in the audience discussion or questions that resonated with you or that you want to speak about?
25:56
Bruce McCulloch
Yeah, no, I was lost, understandably, in some of the Canadian nuance, but I did find it interesting. And there were, you know, a number of interesting questions and contributions from the audience. I was very interested in discussions regarding leniency, because that's something that we, you know, deal with in the U.S. It's the same kind of issues. But the Canada-specific challenges, it was good to hear.
26:20
Bruce McCulloch
I find these exchanges between antitrust practitioners across jurisdictions to be very informative and truly absolutely necessary, as it's very rare for cartel matters to exist in a U.S. only vacuum. I mean, I can't think of one that I've done recently that has that characteristic.
26:43
Bruce McCulloch
Obviously, there are local ones for road paving and things like that. But for the most part, we're dealing with cross-border issues. And clearly, Canada is certainly one that comes up often on matters that have a U.S. component.
27:00
Bruce McCulloch
So, you know, to really practice in this area, it is essential for us to view the bigger picture, which includes other jurisdictions, private litigation, the potential for disbarment, you know, the potential for jail time for individuals. And really, it's a host of other factors. And, you know, so I found all of the, even the Canada-specific discussion, to be enlightening.
27:29
Julia Potter
So my last question for you is sort of to wrap up, and I'm sure it'll be a bit repetitive, what we've already talked about. But if there's anything that you would have said was the highlight or key message coming out of the Town Hall event or something that you were particularly taking away, it'd be great to hear what your thoughts are.
27:45
Julia Potter
Bruce, why don't I start with you on this one?
27:47
Bruce McCulloch
Sure, as I just said, I believe these cross-border exchanges are critical for us as practitioners in this area. It's probably for most of antitrust, but I think cartel is one where it's heightened. And to plug Freshfields a little, we host a cartel roundtable every year around the IBA meetings, and I never miss it as it's important to keep up with the developments around the globe.
28:16
Bruce McCulloch
Also, one other thing you know I took from the event was that, you know, the cartel area is dynamic.
28:26
Bruce McCulloch
While maybe we've seen a decline in the large cross-border matters such as auto parts, we've seen new areas of enforcement in labour, certainly in the US and now potentially in ESG and DEI going forward.
28:43
Bruce McCulloch
You know, so the key message that comes out of this is that, you know, we do need to stay on our toes, you know, and adapt to the issues of the day and those issues could be US-specific, they could be global, and it's an area that is really, you know, important to stay on top of at all times.
29:04
Julia Potter
Yeah, absolutely. Joe, what about you? What was your key takeaway?
29:08
Joe McGrade
Yeah, well, for me, one key takeaway is just that we do have to keep an eye on what's going on south of the border as Canadian antitrust competition practitioners, because the U.S. tends to be a bellwether for the enforcement that we see up here.
29:24
Joe McGrade
So, for example, the focus on wage fixing and no poach kind of started in the States, you saw the big tech case, and then a lot of different enforcement mechanisms or cases that happened down there.
29:35
Joe McGrade
And then the amendments come to the Competition Act and wage fixing, no poach, they're in our cartel provisions now, right? So it's important to stay connected, like Bruce said, and hear what's going on in the States and globally. So thank you, Bruce, for helping us do that.
29:50
Joe McGrade
A key takeaway for me from the meeting was also, you know, the leniency program question is one that continues to stick with me. And I would like to see the Bureau and the PPSC go about making it a little easier for parties to cooperate and doing what they can to mitigate the downsides of that.
30:12
Joe McGrade
On the civil side, that's going to be tricky, but, you know, if debarment seems to be an easy one that maybe they could take a swing at and reduce the burden there or, you know, the extent of the cooperation obligations or,
30:23
Joe McGrade
you know, any other levers they can pull to make that a more and more effective enforcement tool as it has been in the past. So that's something that I'll keep an eye on.
30:32
Julia Potter
That's great. Well, as someone who got to be there in person and have this discussion, it's all quite interesting and it certainly is an evolving field, lots of things to keep our eyes open for. Thank you for this discussion and thank you to the other panellists who are on for the actual event itself.
30:48
Julia Potter
It was all quite interesting to hear everyone's thoughts. Thank you, Bruce. Thank you, Joe. We very much appreciate you attending today, and hopefully our listeners enjoyed this as well.
30:58
Joe McGrade
Great. Thanks, Julia. Happy to be here.
31:01
Bruce McCulloch
Thank you for allowing me to participate.
31:03
Joe McGrade
Yes. And a big thanks to Bruce for traveling up to Canada, for participating in the panel and this podcast. You know, it seems like you're home, so they let you back in after coming up here to help us.
31:15
Joe McGrade
I'm glad to see that.
31:16
Bruce McCulloch
It was smooth, thankfully, yeah.
31:19
Julia Potter
Thank you for listening to this episode of Counterfactual. If you have questions, comments, or ideas for future episodes, please contact us at podcastcommittee@cba.org. Follow on your preferred podcast platform so you don't miss an episode.