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Canada can – and should – crack down on trade-based money laundering

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11 minute read

From the Macdonald Laurier Institute

By Jamie Ferrill for Inside Policy

Neglecting to take decisive action enables organized criminal networks whose activities cause significant harm on our streets and those of our international partners.

Financial crime bears considerable political and economic risk. For the incoming Trump administration, the threat that transnational organized crime and the illicit financial flows pose to global financial stability is a top priority. The threat of tariffs by the Trump administration makes the costs to Canada in enabling global financial crime all too apparent. In addition to the cost of tariffs themselves, the associated reputational risk and loss of confidence in Canada’s financial system has implications for investments, credit, supply chains, and bilateral co-operation and agreements.

Canada’s proximity to major international markets, stable economy, high standard of living, and strong institutions and frameworks make it an attractive place to do business: for both legitimate and criminal enterprises.

Trade is a key contributing sector for Canada’s economic security. It represents two-thirds of Canada’s GDP, and exports alone support nearly 3.3 million Canadian jobs. Trade is also highly vulnerable to criminal exploitation. Ineffective oversight, regulatory complexity, and lagging technology adoption, coupled with a lack of export controls, make it possible to move vast proceeds of crimes, such as those from drug trafficking, human trafficking, corruption, and tax evasion through the global trade system.

These vulnerabilities are well-known by transnational organized crime groups. They are able to effectively move billions of dollars of dirty money through the global trade system every year, a method commonly referred to as Trade-Based Money Laundering (TBML).

While any statistics must be interpreted with caution, evidence shows that TBML is a prevalent method of money laundering.

What is it?

There are several types of Trade-Based Financial Crimes such as terrorism financing through trade, sanctions evasion, and simply trade fraud. However, the TBML definition is necessarily specific. Essentially here, TBML is a money laundering method: the processing of criminal proceeds to disguise their illegal origin. TBML involves the movement of value through the global trade system to obfuscate the illicit origin. This is usually done through document fraud: undervaluing, overvaluing, phantom shipping, or multiple invoicing. Different techniques employ different aspects of the supply chain. And TBML may be just one method used within larger money laundering operations.

By way of example, US authorities allege that two Chinese nationals living in Chicago laundered tens of millions of dollars for the Sinaloa and Jalisco Cartels. Drugs were smuggled into the United States and sold throughout the country. The proceeds from these sales were collected by the Chinese nationals. Those proceeds were used to purchase bulk electronics in the United States, which were then shipped – with a falsified value – to co-conspirators in China, who sold them locally. The legitimacy provided by the electronics sales and the trade transaction provide cover to “clean” proceeds from precursor crime.

Either the importer and/or the exporter of the goods can shift value. Chances here are the electronics shipped were undervalued: on leaving the country, they are declared at a (much) lower value than they are actually worth. The importer in China pays the undervalued invoice, then sells the goods for what they are worth. The profit from those electronics now appears clean, since it was used for a “legitimate” sale. The ensuing value gap can be transferred informally or stored as illicit wealth. The value has now shifted, without fiat currency leaving the country of origin.

But the cycle does not stop there. The value and money itself continue to traverse around the world, through various intermediaries such as financial institutions or cryptocurrency exchanges. It then goes right back into the system and enables the very crimes and organized crime groups that generated it in the first place. It is, in short, the business model of organized crime.

The Canadian problem

Ultimately, the proceeds of crime that have been legitimised through TBML (and other money laundering methods) supports the criminal enterprises that generated the value in the first place. In the example, these are prolific cartels who have been behind the fentanyl crisis, migrant trafficking and abuse, corruption, and widespread violence that destabilizes communities and undermines governments across North America and beyond.

With new actors, drug routes, and ways of doing business, the cartels are very much active in Canada. The Sinaloa cartel in particular has established a significant presence in Canada where it controls the cocaine market, manufactures and distributes fentanyl, and is embedded in local criminal networks. This increases Canada’s role as a strategic location for drug trafficking and a base to export abroad, notably to Europe, the US, and Australia.

Hells Angels, Red Scorpions, ’Ndrangheta, and other organized crime groups are also exploiting Canada’s strategic location using their transnational links. These groups are active in criminal activities that generate proceeds of crime, which they launder through Canadian institutions. From drug trafficking to extortion to human and sex trafficking, the foundation of organized crime relies on generating and maximizing profits. The proceeds generally need to be laundered; otherwise, there are direct lines back to the criminal organizations. They are, without a doubt, exploiting the trade sector; the very sector that provides so much economic security for Canada.

Canada’s regulation, reporting, and prosecution record for money laundering is notoriously weak. Its record for regulation, reporting, and prosecution for trade-based financial crimes, namely here TBML, is even weaker.

As financial institutions and other regulated entities face increased scrutiny following the TD Bank scandal and the Cullen Commission’s inquiry into money laundering in BC, more criminal activity is likely to be displaced into the trade sector and the institutions it comprises.

TBML is difficult for financial institutions to detect, especially given that 80 per cent of trade is done through open accounts. It exploits established trade structures that are meant to protect the system –like documentation and invoicing processes – by manipulating transactions outside traditional payment systems, which requires more sophisticated anti-money laundering strategies to address these hidden vulnerabilities.

Addressing the problem

Trade is a gaping vulnerability. Yet, it attracts minimal attention in countering transnational financial crime. Containing the fentanyl crisis for one requires a collaborative effort to bolster supply chains and the trade sector against financial crime. This means global cooperation, technological advances (such as blockchain technology), appropriate resourcing, more scrutiny on high-risk countries and shippers, and regulatory innovation.

But political will is in short supply. The federal government’s Budget 2024 and the resulting proposed Regulations Amending Certain Regulations Made Under the Proceeds of Crime (Money Laundering) and Terrorism Financing Act will grant CBSA new authorities to counter TBML, but limited resources to make good on them. And CBSA cannot do it alone.

Transnational organized crime and the illicit financial flows that support it poses a threat to global financial stability. The enabling of financial crime hurts Canada’s reputation abroad. With a new political regime emerging in the US, Canada cannot afford to be seen as a weak link. Loss of confidence in a country and its financial system has implications for investments, credit, supply chains, and bilateral cooperation and agreements.

By neglecting to take decisive action, we inadvertently enable organized criminal networks whose activities cause significant harm on our streets and those of our international partners. With profits as their primary driver, it is imperative that we scrutinize financial pathways to disrupt these illicit operations effectively.

Organized crime groups are not bound by privacy laws, bureaucracy, political agendas, and government budgets. They are continually evolving and staying many steps ahead of what Canada is equipped to control: technologically, geographically, strategically, logistically, and tactically. Without appropriate regulations, technological advances, and resources in place, we will continue to be a laggard in countering financial crime.

More systematic change is needed across regulatory frameworks, law enforcement coordination and resourcing, and international partnerships to strengthen oversight, close loopholes, and enhance detection and disruption.  It would be a low-cost signal to the Trump administration that Canada is committed to upping its game.


Jamie Ferrill is senior lecturer in Financial Crime at Charles Sturt University and co-editor of Dirty Money: Financial Crime in Canada.

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Trump threatens additional 50% tariffs on China, urges ‘patience’

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From The Center Square

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President Donald Trump threatened to ratchet up tariffs against China after China upped its own tariffs against the U.S. in response to the president’s tariffs policy announcement earlier this month.

The Chinese Communist Party raised its tariffs on U.S. goods to 34%, ignoring Trump’s warning not to retaliate, which does not include Chinese tariffs on specific U.S. goods like natural gas.

That 34% figure matches the additional tariffs the president put on China in his announcement of the new tariff policy on April 2, an announcement that brought overall tariffs against China to 54%.

Trump argues that tariffs are not the only way China takes advantage of the U.S.

“Yesterday, China issued Retaliatory Tariffs of 34%, on top of their already record setting Tariffs, Non-Monetary Tariffs, Illegal Subsidization of companies, and massive long term Currency Manipulation, despite my warning that any country that Retaliates against the U.S. by issuing additional Tariffs, above and beyond their already existing long term Tariff abuse of our Nation, will be immediately met with new and substantially higher Tariffs, over and above those initially set,” Trump said in a statement online.

“Therefore, if China does not withdraw its 34% increase above their already long term trading abuses by tomorrow, April 8th, 2025, the United States will impose ADDITIONAL Tariffs on China of 50%, effective April 9th,” he continued.

“Additionally, all talks with China concerning their requested meetings with us will be terminated!” the president said. “Negotiations with other countries, which have also requested meetings, will begin taking place immediately.”

Trump also urged Americans to be patient with his tariff policy as stocks continued to decline.

The president unveiled a sweeping set of reciprocal tariffs during a press conference earlier this month, and since that announcement the markets have seen sharp declines.

“The United States has a chance to do something that should have been done DECADES AGO,” Trump said on TruthSocial, his social media platform. “Don’t be Weak! Don’t be Stupid! Don’t be a PANICAN (A new party based on Weak and Stupid people!). Be Strong, Courageous, and Patient, and GREATNESS will be the result!”

Democratic and some Republican critics have blasted the president’s tariffs, a policy previously foreign to the Republican Party in modern politics.

Trump has admitted there will be some pain but argued that the tariffs will reinvigorate domestic manufacturing in the U.S. and raise revenue for the federal government. He also says the tariffs will help the U.S. negotiate better trade deals with other countries, many of which currently charge steep tariffs against the U.S.

Critics argue the tariffs will increase prices for Americans and hurt the economy and U.S. trading relationships.

Trump and his allies have argued the U.S. has been manipulated and taken advantage of in the previous tariff system, all while manufacturing jobs were shipped overseas. Now, they argue, much of our manufacturing is done by one of our greatest adversaries: China.

“Countries from all over the World are talking to us,” Trump said. “Tough but fair parameters are being set. Spoke to the Japanese Prime Minister this morning. He is sending a top team to negotiate! They have treated the U.S. very poorly on Trade. They don’t take our cars, but we take MILLIONS of theirs. Likewise Agriculture, and many other ‘things.’ It all has to change, but especially with CHINA!!!”

Sen. Rand Paul, R-Ky., has helped lead the charge of Republicans who oppose the president’s new trade policy.

“Politicians should pay attention to the millions of investors who are worried that widespread tariffs will lead to a recession,” Paul wrote on X Friday.

Trump’s comments suggest that he is doubling down, not backing off, of his new tariff policy, likely part of the reason markets continued to slide Monday. Trump pointed to other signs of economic health, and his Treasury Secretary Scott Bessent has pointed out that the stock market is only one marker of the economy and one in which half of Americans have no stake.

“Oil prices are down, interest rates are down (the slow moving Fed should cut rates!), food prices are down, there is NO INFLATION, and the long time abused USA is bringing in Billions of Dollars a week from the abusing countries on Tariffs that are already in place,” Trump said. “This is despite the fact that the biggest abuser of them all, China, whose markets are crashing, just raised its Tariffs by 34%, on top of its long term ridiculously high Tariffs (Plus!), not acknowledging my warning for abusing countries not to retaliate. They’ve made enough, for decades, taking advantage of the Good OL’ USA!”

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Trump’s Tariffs: The US, Canada, and the rest of the world

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It’s a mistake to think that Canada and any team of trade allies we can muster will be able to force the US to back down from Trump’s tariffs. Certainly not in the short run.

The US is committed to tariffs.  They know it’s going to create hardships.  They know some businesses are going to fail.  They know some people are going to lose jobs.  They know products are going to cost more.  It’s not that they don’t care about hardships.  They are committing to see if they can withstand these hardships in order to reacquire a lot of the manufacturing jobs that left America over the last three or four decades.

And it’s not all about jobs either.  It’s also about critical industries that have vacated America. It makes no sense that the US would rely on China for pharmaceuticals and rare earth minerals.  Yet that situation is exactly where America finds itself in 2025.

If you’d like a deeper understanding of what is unfolding around the world, this podcast is an absolute ‘must’.

| The Glenn Beck Podcast | Ep 252

Why Conservatives Flipped to Supporting Trump’s Tariffs

Donald Trump is the only one telling the American economy, “You have cancer!”

Kevin Roberts, president of the Heritage Foundation, says, “The treatment is going to be a little painful.” Kevin responds to criticisms that the Heritage Foundation has changed its position on tariffs, explains why the president’s treatment of Canada may be a “tactical error,” and says it’s time for tax cuts, deregulation, and to stop the “fuzzy math happening in Congress” and cut the budget.

They discuss nuclear energy, the Chinese Communist Party, the DOGE, and how the socialist president of Mexico “understands Trump.”

They both agree that we are experiencing the “second American revolution” and lauded the gutting of the Department of Education and the vision of JD Vance, while warning that “not everyone in Silicon Valley is our friend.”

In the end, they have to ask, is Donald Trump moving too fast?

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