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

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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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EXCLUSIVE: Former Biden Climate Czar Apparently Pushed Homeland Security To Ease Up On Chinese Company Linked To Slave Labor

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From the Daily Caller News Foundation

By Nick Pope

Then-national climate adviser Gina McCarthy appears to have met directly with Department of Homeland Security (DHS) Secretary Alejandro Mayorkas in 2021 to urge him to ease up on a Chinese solar company linked to slave labor, according to documents obtained by Protect the Public’s Trust, a government watchdog group.

pre-meeting primer prepared for Mayorkas by staff to get him ready to meet with McCarthy in June 2021 states that McCarthy would “likely discuss the concerns the solar industry has regarding the Department’s enforcement posture on solar products, particularly with regard to Hoshine Silicon Products Company.” The meeting, which McCarthy requested, was scheduled to take place several days after DHS issued a “Withhold Release Order” (WRO) to customs officials to begin seizing shipments of Hoshine solar products because of its connections to slave labor in China’s Xinjiang region, an area known as ground zero for the Chinese government’s genocidal repression of Uyghur Muslims.

DHS still lists Hoshine Silicon Industry and its subsidiaries as entities manufacturing products that use slave labor in violation of the Uyghur Forced Labor Prevention Act.

“The impacts of the Hoshine Withold (sic) Release Order (WRO) include the detention of goods and their effect on consumer and investor confidence in solar products, projects, and the industry; concern is growing that this will affect the industry’s ability to meet the nation’s clean energy goals,” the primer for Mayorkas reads.

PPT Documents – Hoshine + DHS by Nick Pope

“Industry indicates that the Hoshine WRO limits their ability to meet demand for solar panels without liability,” the memo continues. “Industry expressed that the WRO’s impact on consumer and investor confidence has resulted in cancelled orders and investments and has put jobs at risk.”

Chinese companies dominate the global supply chains for green energy products including solar panels, and a large share of the world’s polysilicon — a key ingredient for the production of solar panels — comes from the Xinjiang region specifically, The New York Times reported in June 2021 following the announcement of the Hoshine WRO. The Hoshine WRO illustrates a wider problem for the Biden administration whereby it works to cut China and Chinese slave labor-tied companies out of the U.S. solar supply chain without going too far and suffocating American solar companies that rely on Chinese component parts at the expense of the government’s lofty long-term green energy goals.

For example, about one year after the scheduled Mayorkas-McCarthy meeting, the Biden administration opted to waive tariffs on Chinese solar products in June 2022 amid concerns that the levies could crush the American solar industry before reinstating the duties in June 2024. Some American solar firms and executives said that Chinese companies managed to undercut U.S. solar production during the period of time when the tariffs were not being enforced.

Mayorkas stated publicly that “the United States will not tolerate modern-day slavery in our supply chains” on the day DHS announced the WRO against Hoshine.

The memo briefed Mayorkas on several options that McCarthy was likely to bring up at the meeting, including possible proposals to phase in enforcement to reassure the spooked market, increase transparency for the public with respect to DHS’ Hoshine restrictions or to create a “de minimis” threshold for the amount of slave labor-linked polysilicon in a given imported product. Mayorkas’ staff also laid out detailed “pros” and “cons” for each of the suggestions they expected McCarthy to make in the meeting.

“DHS made a rational and moral judgement about products from a company and a nation that uses the forced labor of Uyghurs and other ethnic and political prisoners,” Michael Chamberlain, executive director of Protect the Public’s Trust, told the Daily Caller News Foundation. “But it seems human rights are a secondary consideration for the people charged with implementing the Biden administration’s green agenda and their counterparts in the clean energy industry. It’s hard to see what’s ‘clean’ about solar panels made with slave labor.”

McCarthy, who was the head of the Environmental Protection Agency (EPA) for the Obama administration, served as the Biden administration’s national climate adviser before leaving the government in 2022. In between her stints in the Obama and Biden administrations, McCarthy worked as the president of the Natural Resources Defense Council (NRDC), a major environmental activist group that has a presence in China and is registered with or supervised by Chinese government institutions like the Beijing Municipal Public Security Bureau and the State Forestry and Grassland Administration, according to NRDC’s Chinese language website.

Notably, the documents obtained by Protect the Public’s Trust also include a similar briefing memo meant to prepare him for an October 2021 meeting with the American Clean Power Association about DHS’ enforcement actions against slave labor-linked solar products. That particular document spells out how representatives for the green energy trade group were likely to push for answers about the administration’s conflicting goals of rooting out slave labor from solar supply chains and quickly standing up a robust domestic solar industry.

DHS and McCarthy’s spokesperson did not respond to multiple requests for comment from the DCNF.

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Public Accounts of Canada Report Buried on Last Day of Sitting Session

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The Opposition with Dan Knight

Trudeau Government Hides Exploding Deficit and Fiscal Mismanagement Amid Chaos and Distraction

Well, folks, here we go again. The Trudeau government—masterclass in obfuscation, fiscal recklessness, and zero accountability—just pulled off another slick political maneuver. This time, it’s the Public Accounts of Canada 2024, a document that should be front-page news, but this news bite is buried so deep in the news cycle you’d think it was radioactive.

Here’s what’s happening: the government dropped its final, audited financial statements for the fiscal year on the last day of the parliamentary sitting session, when no one’s watching. Why? Because it’s bad. Really bad. Let’s connect the dots.

First, we had the Fall Economic Statement released just yesterday, a forward-looking document that’s basically a glossy brochure for Trudeau’s latest spending spree. That’s what the media focused on. But the Public Accounts—that’s where you see the hard, cold truth: the deficit is exploding, hitting $61.9 billion, and Canada’s finances are way past the so-called “guardrails” Trudeau and Freeland promised us.

Let’s not forget, those guardrails were supposed to limit deficits to $40 billion, but Trudeau blew right past that, overspending by more than $20 billion. And now they’re scrambling to hide the numbers because they know Canadians will not tolerate this reckless fiscal mismanagement any longer.

Ah, yes, Chrystia Freeland—the “fiscally responsible” finance minister—who just resigned in the middle of this chaos. What are the odds? She’s out, claiming “irreconcilable differences” with Trudeau’s economic policies. Translation: she knew the books are in tatters, and she didn’t want her name on them when the inevitable reckoning comes.

Now ask yourself: if everything was fine, if Canada’s economy was strong and the government was keeping its promises, wouldn’t Trudeau and his pals want to shout this from the rooftops? Wouldn’t they want the opposition to read every page of those Public Accounts? Instead, they slid the report across the table on the last possible day—while the media was distracted, MPs were packing up, and Freeland was running for the hills.

This is the oldest trick in the book. When governments screw up, they don’t admit it. They bury the evidence, release it late, or throw out a flashy distraction. Trudeau just did all three in one week: the Fall Economic Statement, full of nice words but exposing Trudeau’s reckless spending; Chrystia Freeland’s resignation, a clear sign even she wanted no part of it; and Anita Anand quietly releasing the Public Accounts on the last day of the sitting session, hoping no one would notice as Trudeau’s crumbling leadership sucks up all the oxygen in the news cycle.

What’s in those Public Accounts that Trudeau doesn’t want you to see? Deficits far larger than what he promised? Ballooning spending on programs that are failing Canadians? Spiraling interest costs on our record-breaking debt? Likely all of the above.

Here’s the bottom line: Trudeau’s government has lost control of the country’s finances. They’re driving Canada into economic oblivion, and when the consequences hit, it won’t be politicians who pay the price. It’ll be hardworking Canadians—your taxes, your savings, your livelihoods.

And what does Trudeau do? He hides the truth, covers it up, and hopes you’re too distracted to care. This is what contempt for democracy looks like, and it’s a disgrace. Canadians deserve better.

That’s the real story here—Trudeau’s government has a deficit of trust, a deficit of competence, and now, a fiscal deficit so big it makes Freeland want to quit. You couldn’t make it up if you tried.

Stay tuned, folks, because this isn’t over. When the numbers come out, they’ll tell a story Trudeau can’t hide forever—and that story won’t be pretty.

What is the Public Accounts of Canada?

The Public Accounts of Canada is the official, audited financial report of the Government of Canada, providing a final and comprehensive overview of the federal government’s finances for the fiscal year, which runs from April 1 to March 31.

  • This document is produced annually by the Receiver General for Canada and is audited by the Auditor General of Canada to ensure its accuracy, reliability, and adherence to public sector accounting standards.
  • It includes detailed information about revenues, expenditures, deficits or surpluses, debt, and all financial activities of government departments, agencies, and Crown corporations.

The Public Accounts is a backward-looking document: it reports the final, audited numbers of what has already happened financially over the previous fiscal year.


How is it Different from the Fall Economic Statement?

The Fall Economic Statement is a forward-looking financial update presented by the government midway through the fiscal year, typically in November or December. It outlines the government’s current economic outlook, updates revenue and spending projections, and provides an estimate of deficits or surpluses for the upcoming years.

Key Differences Between the Public Accounts and the Fall Economic Statement

The Public Accounts of Canada and the Fall Economic Statement serve distinct purposes in the government’s financial reporting, primarily differing in their focus, timing, and level of scrutiny.

  • Timeframe:
    The Public Accounts are backward-looking, presenting the final, audited financial results for the previous fiscal year (April 1 to March 31). In contrast, the Fall Economic Statement is forward-looking, providing forecasts and plans for the current and upcoming fiscal years.
  • Purpose:
    The Public Accounts offer a definitive and detailed overview of the government’s financial performance, focusing on accountability and transparency. It includes actual revenues, expenditures, deficits, and debt levels. Meanwhile, the Fall Economic Statement serves as a mid-year economic and fiscal update, often outlining new spending initiatives, policies, and projections for future budgets.
  • Audit Status:
    A key distinction is that the Public Accounts are audited by the Auditor General of Canada. This means the numbers are verified and considered reliable. In contrast, the Fall Economic Statement consists of projections prepared by the Department of Finance and is not independently audited.
  • Content:
    The Public Accounts present actual, finalized financial data, including where taxpayer money was spent, how much debt was accumulated, and whether the deficit or surplus matched previous promises. The Fall Economic Statement, however, focuses on estimates—projecting government spending, deficits, and economic growth into the future.
  • Timing:
    Traditionally, the Public Accounts are tabled in the fall, typically between late September and October. This timing ensures that Parliament and the public have an opportunity to analyze the government’s financial performance before the year ends. The Fall Economic Statement, on the other hand, is released later in the fall, usually in November or December, as a political and economic update.

The Bottom Line

The Public Accounts of Canada is about facts and accountability, providing hard, audited numbers on what the government actually did with its finances. The Fall Economic Statement is about forecasts and priorities, giving Canadians a sense of where the government intends to go financially and politically. While both are important, only the Public Accounts holds the government accountable for its actual financial record.


Why it Matters

  • The Public Accounts hold the government accountable for its actual spending and deficits. Because they are audited, these numbers are considered the final word on the government’s fiscal performance.
  • The Fall Economic Statement, however, is a political document. It forecasts future spending, reflects policy priorities, and often contains new announcements or programs. While it gives an idea of where the government thinks finances are headed, it’s not final or independently audited.

Final Thoughts

The Public Accounts of Canada is a finalized, audited report that shows where the government’s money actually went—the truth, the real numbers, no spin, no glossy brochures. It’s the hard, cold record of how this government spent your hard-earned tax dollars. The Fall Economic Statement, by contrast, is just a wish list—a forward-looking document full of lofty promises, political spin, and projections that rarely match reality. One is about accountability. The other is about politics and promises.

Both matter, but only one tells Canadians the hard truth about the state of our country’s finances. And let’s be clear: this Public Accounts report isn’t going away. Come the next session, the Public Accounts Committee will be digging through every page of this government’s fiscal mismanagement. They’ll expose what Trudeau, Freeland, and now LeBlanc have done to this country’s finances—runaway deficits, bloated spending, mountains of debt our kids will have to pay off.

And where is the NDP in all this? They’ll criticize just enough to keep up appearances, but let’s not pretend they’re not part of the problem. They’ve traded your children’s future for a seat at Trudeau’s crumbling table. For what? A dental plan? A plan that sounds great on paper, but let’s face it: what good is getting your teeth cleaned when you can’t afford to put food on the table? What good is a government that pretends to care about affordability while driving this country further into debt?

Canadians deserve better than this. Our families, our children, and our seniors deserve better. This country was built on the promise of hard work, sacrifice, and the dream of a better life for the next generation. But that dream is being stolen—piece by piece—by a government with no respect for fiscal responsibility, no sense of accountability, and no real plan for the future. Instead, they’re mortgaging your kids’ future, spending money we don’t have on programs we can’t afford, all to cling to power a little longer.

This is about more than budgets and deficits. This is about Canada—about the values that built this country. We are a nation of workers, builders, and innovators. We are a people who believe in living within our means, taking responsibility for ourselves and our families, and handing something better to the next generation. That’s what makes Canada strong. And that’s what this government is destroying—recklessly, selfishly, and without shame.

Canadians are tired of the misplaced priorities. Tired of being told there’s no money for veterans, farmers, or small businesses while this government burns through billions on their pet projects and political handouts. Tired of watching their taxes go up, their cost of living skyrocket, and their dreams slip further and further out of reach.

It’s time to stop this madness. Canadians deserve a government that respects their sacrifices, lives within its means, and understands that every dollar it spends belongs to you—not them. This country is not Justin Trudeau’s personal playground. It’s your country. It’s our country. And it’s time to take it back.

We need an election. Canadians need to send a message to this government that enough is enough. We will not stand by while they gamble away our future. We will not let them bury the truth in backroom releases and holiday distractions. This is our Canada, and it’s time to fight for it. For our families, for our future, and for the country we love.

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