Business
Canada can – and should – crack down on trade-based money laundering
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.
Prince Rupert Port Authority CEO Shaun Stevenson. Photo courtesy Prince Rupert Port Authority
From the Canadian Energy Centre
A strategic gateway to the world
Tucked into the north coast of B.C. is the deepest natural harbour in North America and the port with the shortest travel times to Asia.
With growing capacity for exports including agricultural products, lumber, plastic pellets, propane and butane, it’s no wonder the Port of Prince Rupert often comes up as a potential new global gateway for oil from Alberta, said CEO Shaun Stevenson.
Thanks to its location and natural advantages, the port can efficiently move a wide range of commodities, he said.
That could include oil, if not for the federal tanker ban in northern B.C.’s coastal waters.
The Port of Prince Rupert on the north coast of British Columbia. Photo courtesy Prince Rupert Port Authority
“Notwithstanding the moratorium that was put in place, when you look at the attributes of the Port of Prince Rupert, there’s arguably no safer place in Canada to do it,” Stevenson said.
“I think that speaks to the need to build trust and confidence that it can be done safely, with protection of environmental risks. You can’t talk about the economic opportunity before you address safety and environmental protection.”
Safe Transit at Prince Rupert
About a 16-hour drive from Vancouver, the Port of Prince Rupert’s terminals are one to two sailing days closer to Asia than other West Coast ports.
The entrance to the inner harbour is wider than the length of three Canadian football fields.
The water is 35 metres deep — about the height of a 10-storey building — compared to 22 metres at Los Angeles and 16 metres at Seattle.
Shipmasters spend two hours navigating into the port with local pilot guides, compared to four hours at Vancouver and eight at Seattle.
“We’ve got wide open, very simple shipping lanes. It’s not moving through complex navigational channels into the site,” Stevenson said.
A Port on the Rise
The Prince Rupert Port Authority says it has entered a new era of expansion, strengthening Canada’s economic security.
The port estimates it anchors about $60 billion of Canada’s annual global trade today. Even without adding oil exports, Stevenson said that figure could grow to $100 billion.
“We need better access to the huge and growing Asian market,” said Heather Exner-Pirot, director of energy, natural resources and environment at the Macdonald-Laurier Institute.
“Prince Rupert seems purpose-built for that.”
Roughly $3 billion in new infrastructure is already taking shape, including the $750 million rail-to-container CANXPORT transloading complex for bulk commodities like specialty agricultural products, lumber and plastic pellets.
The Ridley Island Propane Export Terminal, Canada’s first marine propane export terminal, started shipping in May 2019. Photo courtesy AltaGas Ltd.
Canadian Propane Goes Global
A centrepiece of new development is the $1.35-billion Ridley Energy Export Facility — the port’s third propane terminal since 2019.
“Prince Rupert is already emerging as a globally significant gateway for propane exports to Asia,” Exner-Pirot said.
Thanks to shipments from Prince Rupert, Canadian propane – primarily from Alberta – has gone global, no longer confined to U.S. markets.
More than 45 per cent of Canada’s propane exports now reach destinations outside the United States, according to the Canada Energy Regulator.
“Twenty-five per cent of Japan’s propane imports come through Prince Rupert, and just shy of 15 per cent of Korea’s imports. It’s created a lift on every barrel produced in Western Canada,” Stevenson said.
“When we look at natural gas liquids, propane and butane, we think there’s an opportunity for Canada via Prince Rupert becoming the trading benchmark for the Asia-Pacific region.”
That would give Canadian production an enduring competitive advantage when serving key markets in Asia, he said.
Deep Connection to Alberta
The Port of Prince Rupert has been a key export hub for Alberta commodities for more than four decades.
Through the Alberta Heritage Savings Trust Fund, the province invested $134 million — roughly half the total cost — to build the Prince Rupert Grain Terminal, which opened in 1985.
The largest grain terminal on the West Coast, it primarily handles wheat, barley, and canola from the prairies.
The Prince Rupert Grain Terminal. Photo courtesy Prince Rupert Port Authority
Today, the connection to Alberta remains strong.
In 2022, $3.8 billion worth of Alberta exports — mainly propane, agricultural products and wood pulp — were shipped through the Port of Prince Rupert, according to the province’s Ministry of Transportation and Economic Corridors.
In 2024, Alberta awarded a $250,000 grant to the Prince Rupert Port Authority to lead discussions on expanding transportation links with the province’s Industrial Heartland region near Edmonton.
Handling Some of the World’s Biggest Vessels
The Port of Prince Rupert could safely handle oil tankers, including Very Large Crude Carriers (VLCCs), Stevenson said.
“We would have the capacity both in water depth and access and egress to the port that could handle Aframax, Suezmax and even VLCCs,” he said.
“We don’t have terminal capacity to handle oil at this point, but there’s certainly terminal capacities within the port complex that could be either expanded or diversified in their capability.”
Market Access Lessons From TMX
Like propane, Canada’s oil exports have gained traction in Asia, thanks to the expanded Trans Mountain pipeline and the Westridge Marine Terminal near Vancouver — about 1,600 kilometres south of Prince Rupert, where there is no oil tanker ban.
The Trans Mountain expansion project included the largest expansion of ocean oil spill response in Canadian history, doubling capacity of the West Coast Marine Response Corporation.
The K.J. Gardner is the largest-ever spill response vessel in Canada. Photo courtesy Western Canada Marine Response Corporation
The Canada Energy Regulator (CER) reports that Canadian oil exports to Asia more than tripled after the expanded pipeline and terminal went into service in May 2024.
As a result, the price for Canadian oil has gone up.
The gap between Western Canadian Select (WCS) and West Texas Intermediate (WTI) has narrowed to about $12 per barrel this year, compared to $19 per barrel in 2023, according to GLJ Petroleum Consultants.
Each additional dollar earned per barrel adds about $280 million in annual government royalties and tax revenues, according to economist Peter Tertzakian.
The Road Ahead
There are likely several potential sites for a new West Coast oil terminal, Stevenson said.
“A pipeline is going to find its way to tidewater based upon the safest and most efficient route,” he said.
“The terminal part is relatively straightforward, whether it’s in Prince Rupert or somewhere else.”
Under Canada’s Marine Act, the Port of Prince Rupert’s mandate is to enable trade, Stevenson said.
“If Canada’s trade objectives include moving oil off the West Coast, we’re here to enable it, presuming that the project has a mandate,” he said.
“If we see the basis of a project like this, we would ensure that it’s done to the best possible standard.”
From the Fraser Institute
By Gary Mauser
The government told Cape Bretoners they had two weeks to surrender their firearms to qualify for reimbursement or “buyback.” The pilot project netted a grand total of 22 firearms.
Five years after then-prime minister Justin Trudeau banned more than 100,000 types of so-called “assault-style firearms,” the federal government recently made the first attempt to force Canadians to surrender these firearms.
It didn’t go well.
The police chief in Cape Breton, Nova Scotia, volunteered to run a pilot “buyback” project, which began last month. The government told Cape Bretoners they had two weeks to surrender their firearms to qualify for reimbursement or “buyback.” The pilot project netted a grand total of 22 firearms.
This failure should surprise no one. Back in 2018, a survey of “stakeholders” warned the government that firearms owners wouldn’t support such a gun ban. According to Prime Minister Carney’s own Privy Council Office the “program faces a risk of non-compliance.” And federal Public Safety Minister Gary Anandasangaree was recently recorded admitting that the “buyback” is a partisan maneuver, and if it were up to him, he’d scrap it. What’s surprising is Ottawa’s persistence, particularly given the change in the government and the opportunity to discard ineffective policies.
So what’s really going on here?
One thing is for certain—this program is not, and never has been, about public safety. According to a report from the federal Department of Justice, almost all guns used in crimes in Canada, including in big cities such as Toronto, are possessed illegally by criminals, with many smuggled in from the United States. And according to Ontario’s solicitor general, more than 90 per cent of guns used in crimes in the province are illegally imported from the U.S. Obviously, the “buyback” program will have no effect on these guns possessed illegally by criminals.
Moreover, Canadian firearms owners are exceptionally law-abiding and less likely to commit murder than other Canadians. That also should not be surprising. To own a firearm in Canada, you must obtain a Possession and Acquisition Licence (PAL) from the RCMP after initial vetting and daily monitoring for possible criminal activity. Between 2000 and 2020, an average of 12 PAL-holders per year were accused of homicide, out of approximately two million PAL-holders. During that same 10-year period, the PAL-holder firearms homicide rate was 0.63 (per 100,000 PAL-holders) compared to 0.72 (per 100,000 adult Canadians)—that’s 14 per cent higher than the rate for PAL-holders.
In other words, neither the so-called “assault-style firearms” nor their owners pose a threat to the public.
And the government’s own actions belie its claims. If these firearms are such a threat to Canadians, why slow-roll the “buyback” program? If inaction increased the likelihood of criminality by law-abiding firearms owners, why wait five years before launching a pilot program in a small community such as Cape Breton? And why continue to extend the amnesty period for another year, which the government did last month at the same time its pilot project netted a mere 22 firearms?
To ask those questions is to answer them.
Another question—how much will the “buyback” program cost taxpayers?
The government continues to block any attempt to disclose the full financial costs (although the Canadian Taxpayers Federation has launched a lawsuit to try to force the government to honour its Access to Information Act request). But back in 2020 the Trudeau government said it would cost $200 million to compensate firearms owners (although the Parliamentary Budget Officer said compensation costs could reach $756 million). By 2024, the program had spent $67.2 million—remember, that’s before it collected a single gun. The government recently said the program’s administrative costs (safe storage, destruction of hundreds of thousands of firearms, etc.) would reach an estimated $1.8 billion. And according to Carney’s first budget released in November, his government will spend $364 million on the program this fiscal year—at a time of massive federal deficits and debt.
This is reminiscent of the Chretien government’s gun registry fiasco, which wound up costing more than $2 billion even after then-justice minister Allan Rock promised the registry program would “almost break even” after an $85 million initial cost. The Harper government finally scrapped the registry in 2012.
As the Carney government clings to the policies of its predecessor, Canadians should understand the true nature of Ottawa’s gun “buyback” program and its costs.
Gary Mauser
Professor Emeritus, Simon Fraser University
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