The appellants challenged search warrants issued under the Mutual Legal Assistance in Criminal Matters Act in aid of foreign money laundering investigations, arguing that once improperly obtained material was excised, the warrants lacked sufficient foundation and should also be quashed for abuse of process.
The court held that review of the warrants was governed by the Garofoli standard, not a de novo reconsideration of whether the reviewing judge would himself or herself have issued the warrants.
Applying that standard, the remaining information was sufficient and also established that an evidence-gathering order under s. 18 would not have been appropriate.
The court further held that allegations concerning Charter breaches and investigative abuse were more properly addressed at the s. 15 hearing on whether seized materials should be sent to the requesting states.
The appeal was dismissed.
