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.

Related Topics:#InsidePolicy #MacdonaldLaurierInstitute CanadaFinancialCrime CanadaOrganizedCrime JamieFerrill TradeBasedMoneyLaundering

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TD Bank Account Closures Expose Chinese Hybrid Warfare Threat

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TD Bank Account Closures Expose Chinese Hybrid Warfare Threat

Published on April 29, 2025

Todayville

From the Frontier Centre for Public Policy

By Scott McGregor

Scott McGregor warns that Chinese hybrid warfare is no longer hypothetical—it’s unfolding in Canada now. TD Bank’s closure of CCP-linked accounts highlights the rising infiltration of financial interests. From cyberattacks to guanxi-driven influence, Canada’s institutions face a systemic threat. As banks sound the alarm, Ottawa dithers. McGregor calls for urgent, whole-of-society action before foreign interference further erodes our sovereignty.

Chinese hybrid warfare isn’t coming. It’s here. And Canada’s response has been dangerously complacent

The recent revelation by The Globe and Mail that TD Bank has closed accounts linked to pro-China groups—including those associated with former Liberal MP Han Dong—should not be dismissed as routine risk management. Rather, it is a visible sign of a much deeper and more insidious campaign: a hybrid war being waged by the Chinese Communist Party (CCP) across Canada’s political, economic and digital spheres.

TD Bank’s move—reportedly driven by “reputational risk” and concerns over foreign interference—marks a rare, public signal from the private sector. Politically exposed persons (PEPs), a term used in banking and intelligence circles to denote individuals vulnerable to corruption or manipulation, were reportedly among those flagged. When a leading Canadian bank takes action while the government remains hesitant, it suggests the threat is no longer theoretical. It is here.

Hybrid warfare refers to the use of non-military tools—such as cyberattacks, financial manipulation, political influence and disinformation—to erode a nation’s sovereignty and resilience from within. In The Mosaic Effect: How the Chinese Communist Party Started a Hybrid War in America’s Backyard, co-authored with Ina Mitchell, we detailed how the CCP has developed a complex and opaque architecture of influence within Canadian institutions. What we’re seeing now is the slow unravelling of that system, one bank record at a time.

Financial manipulation is a key component of this strategy. CCP-linked actors often use opaque payment systems—such as WeChat Pay, UnionPay or cryptocurrency—to move money outside traditional compliance structures. These platforms facilitate the unchecked flow of funds into Canadian sectors like real estate, academia and infrastructure, many of which are tied to national security and economic competitiveness.

Layered into this is China’s corporate-social credit system. While framed as a financial scoring tool, it also functions as a mechanism of political control, compelling Chinese firms and individuals—even abroad—to align with party objectives. In this context, there is no such thing as a genuinely independent Chinese company.

Complementing these structural tools is guanxi—a Chinese system of interpersonal networks and mutual obligations. Though rooted in trust, guanxi can be repurposed to quietly influence decision-makers, bypass oversight and secure insider deals. In the wrong hands, it becomes an informal channel of foreign control.

Meanwhile, Canada continues to face escalating cyberattacks linked to the Chinese state. These operations have targeted government agencies and private firms, stealing sensitive data, compromising infrastructure and undermining public confidence. These are not isolated intrusions—they are part of a broader effort to weaken Canada’s digital, economic and democratic institutions.

The TD Bank decision should be seen as a bellwether. Financial institutions are increasingly on the front lines of this undeclared conflict. Their actions raise an urgent question: if private-sector actors recognize the risk, why hasn’t the federal government acted more decisively?

The issue of Chinese interference has made headlines in recent years, from allegations of election meddling to intimidation of diaspora communities. TD’s decision adds a new financial layer to this growing concern.

Canada cannot afford to respond with fragmented, reactive policies. What’s needed is a whole-of-society response: new legislation to address foreign interference, strengthened compliance frameworks in finance and technology, and a clear-eyed recognition that hybrid warfare is already being waged on Canadian soil.

The CCP’s strategy is long-term, multidimensional and calculated. It blends political leverage, economic subversion, transnational organized crime and cyber operations. Canada must respond with equal sophistication, coordination and resolve.

The mosaic of influence isn’t forming. It’s already here. Recognizing the full picture is no longer optional. Canadians must demand transparency, accountability and action before more of our institutions fall under foreign control.

Scott McGregor is a defence and intelligence veteran, co-author of The Mosaic Effect: How the Chinese Communist Party Started a Hybrid War in America’s Backyard, and the managing partner of Close Hold Intelligence Consulting Ltd. He is a senior security adviser to the Council on Countering Hybrid Warfare and a former intelligence adviser to the RCMP and the B.C. Attorney General. He writes for the Frontier Centre for Public Policy.

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Major automakers push congress to block California’s 2035 EV mandate

Published on April 28, 2025

Todayville

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Quick Hit:

Major automakers are urging Congress to intervene and halt California’s aggressive plan to eliminate gasoline-only vehicles by 2035. With the Biden-era EPA waiver empowering California and 11 other states to enforce the rule, automakers warn of immediate impacts on vehicle availability and consumer choice. The U.S. House is preparing for a critical vote to determine if California’s sweeping environmental mandates will stand.

Key Details:

Automakers argue California’s rules will raise prices and limit consumer choices, especially amid high tariffs on auto imports.
The House is set to vote this week on repealing the EPA waiver that greenlit California’s mandate.
California’s regulations would require 35% of 2026 model year vehicles to be zero-emission, a figure manufacturers say is unrealistic.

Diving Deeper:

The Alliance for Automotive Innovation, representing industry giants such as General Motors, Toyota, Volkswagen, and Hyundai, issued a letter Monday warning Congress about the looming consequences of California’s radical environmental regulations. The automakers stressed that unless Congress acts swiftly, vehicle shipments across the country could be disrupted within months, forcing car companies to artificially limit sales of traditional vehicles to meet electric vehicle quotas.

California’s Air Resources Board rules have already spread to 11 other states—including New York, Massachusetts, and Oregon—together representing roughly 40% of the entire U.S. auto market. Despite repeated concerns from manufacturers, California officials have doubled down, insisting that their measures are essential for meeting lofty greenhouse gas reduction targets and combating smog. However, even some states like Maryland have recognized the impracticality of California’s timeline, opting to delay compliance.

A major legal hurdle complicates the path forward. The Government Accountability Office ruled in March that the EPA waiver issued under former President Joe Biden cannot be revoked under the Congressional Review Act, which requires only a simple Senate majority. This creates uncertainty over whether Congress can truly roll back California’s authority without more complex legislative action.

The House is also gearing up to tackle other elements of California’s environmental regime, including blocking the state from imposing stricter pollution standards on commercial trucks and halting its low-nitrogen oxide emissions regulations for heavy-duty vehicles. These moves reflect growing concerns that California’s progressive regulatory overreach is threatening national commerce and consumer choice.

Under California’s current rules, the state demands that 35% of light-duty vehicles for the 2026 model year be zero-emission, scaling up rapidly to 68% by 2030. Industry experts widely agree that these targets are disconnected from reality, given the current slow pace of electric vehicle adoption among the broader American public, particularly in rural and lower-income areas.

California first unveiled its plan in 2020, aiming to make at least 80% of new cars electric and the remainder plug-in hybrids by 2035. Now, under President Donald Trump’s leadership, the U.S. Transportation Department is working to undo the aggressive fuel economy regulations imposed during former President Joe Biden’s term, offering a much-needed course correction for an auto industry burdened by regulatory overreach.

As Congress debates, the larger question remains: Will America allow one state’s left-wing environmental ideology to dictate terms for the entire country’s auto industry?