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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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Labor Department cancels “America Last” spending spree spanning five continents

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Quick Hit:

The U.S. Department of Labor has scrapped nearly $600 million in foreign aid grants, including $10 million aimed at promoting “gender equity in the Mexican workplace.”

Key Details:

  • Labor Secretary Lori Chavez-DeRemer and Deputy Secretary Keith Sonderling were credited with delivering $237 million in savings through the latest round of canceled programs.

  • Among the defunded initiatives: $12.2 million for “worker empowerment” efforts in South America, $6.25 million to improve labor rights in Central American agriculture, and $5 million to promote women’s workplace participation in West Africa.

  • The Department of Government Efficiency described the cuts as necessary to realign U.S. labor policy with national interests and applauded the elimination of all 69 international grants managed by the Bureau of International Labor Affairs.

 

Diving Deeper:

The U.S. Department of Labor on Wednesday canceled $577 million in foreign aid grants, including a controversial $10 million program aimed at promoting “gender equity in the Mexican workplace,” according to documents obtained by The Washington Post. The sweeping decision to terminate all 69 active international labor grants comes as part of a larger restructuring effort led by John Clark, a senior DOL official appointed during the Trump administration.

Clark directed the department’s Bureau of International Labor Affairs (ILAB) to shut down its entire grant portfolio, citing a “lack of alignment with agency priorities and national interest.” The memo explaining the cancellations was first reported by The Washington Post and highlights a broader shift in federal labor policy toward domestic-focused initiatives.

Among the eliminated grants were high-dollar projects that had drawn criticism from watchdog groups for years. These included $12.2 million designated for “worker empowerment in South America,” $6.25 million targeting labor conditions in Honduras, Guatemala, and El Salvador, and $5 million to elevate women’s workplace participation in West Africa. Other defunded programs involved $4.3 million to support foreign migrant workers in Malaysia, $3 million to improve social protections for internal migrants in Bangladesh, and $3 million to promote “safe and inclusive work environments” in Lesotho.

The Department of Government Efficiency, also involved in the review, labeled the grants as “America Last” initiatives, and pointed to the lack of measurable outcomes and limited benefits to American workers. The agency commended the leadership of Labor Secretary Lori Chavez-DeRemer and Deputy Secretary Keith Sonderling for securing $237 million in savings during this round alone.

The cuts mark the second major cost-saving move under Chavez-DeRemer’s leadership in as many weeks. Just days earlier, she canceled an additional $33 million in funding, including a $1.5 million grant focused on increasing transparency in Uzbekistan’s cotton sector. Chavez-DeRemer, a former Republican congresswoman from Oregon, was confirmed as Labor Secretary on March 11th by a bipartisan Senate vote of 67-32.

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Elon Musk, DOGE officials reveal ‘astonishing’ government waste, fraud in viral interview

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From LifeSiteNews

By Doug Mainwaring

Elon Musk said that ‘the sheer amount of waste and fraud’ in federal agencies, is ‘astonishing’ and that DOGE is cutting ‘$4 billion a day’ in misused taxpayer funds.

In a remarkable Fox News interview, Department of Government Efficiency (DOGE) founder Elon Musk and top officials of the DOGE team offered stunning, often infuriating, insights into how the federal government functions.

The interview, which has garnered well over 10 million online views on X in less than 24 hours, provided one extreme example after another of government mismanagement, excess, waste, and fraud while simultaneously promising a future where the D.C. Leviathan is tamed and restored to its proper, efficient role.

The new Deputy Director of the Office of Management and Budget (OMB), former U.S. House Rep. Dan Bishop, averred that the DOGE A-Team interview was the “most amazing and significant half-hour in TV history.” 

Musk was joined by DOGE team members Steve Davis, Joe Gebbia, Aram Moghaddassi, Brad Smith, Anthony Armstrong, Tom Krause, and Tyler Hassen – all successful businessmen and entrepreneurs in their own rights – to describe the widespread systemic weaknesses and failures at the Internal Revenue Service (IRS), the National Institutes of Health (NIH), the Department of Health and Human Services (HHS), the Social Security Administration (SSA), and more.  

Fox host Bret Baier described the group as “Silicon Valley colliding with government.”

“This is a revolution. And I think it might be the biggest revolution in government since the original revolution,” said Musk during the discussion.  

“But at the end of the day, America’s going to be in much better shape,” he promised.

“America will be solvent. The critical programs that people depend upon will work, and it’s going to be a fantastic future.” 

Musk said that the most stunning thing he’s discovered during the early phases of DOGE is “the sheer amount of waste and fraud in government. It is astonishing. It’s mind-blowing.”

Musk cited the example of a simple 10-question National Park online survey for which the government was charged nearly $1 billion and which in the end served no purpose.

“I think we will accomplish most of the work required to reduce the deficit by a trillion dollars within [130 days],” he predicted. “Our goal is to reduce the waste and fraud by $4 billion a day, every day, seven days a week. And so far, we are succeeding.”

Billionaire Airbnb co-founder Joe Gebbia, is working to digitize the retirement process for government employees, which is currently stuck using 1950s technology, housed in a Pennsylvania cave.

“It’s an injustice to civil servants who are subjected to these processes that are older than the age of half the people watching the show tonight,” said Gebbia. “We really believe that the government can have an Apple store-like experience, beautifully designed, great user experience, modern systems.”  

“The retirement process is all by paper, literally, with people carrying paper and manila envelopes into this gigantic mine,” added Musk, limiting the number of federal employees who can retire to no more than 8,000 per month.

Gebbia expects to have the antiquated system updated and overhauled in a matter of months.  

“The two improvements that we’re trying to make to Social Security are helping people that legitimately get benefits protect them from fraud that they experience every day on a routine basis and also make the experience better,” said DOGE software engineer Aram Moghaddassi.

He offered an amazing statistic: “When you want to change your (direct deposit) bank account, you can call Social Security. We learned 40% of the phone calls that they get are from fraudsters” who are attempting to commandeer retired seniors’ benefit payments.

“What we’re doing will help their benefits,” assured Musk. “As a result of the work of DOGE, legitimate recipients of social security will receive more money, not less money.” 

“There are over 15 million people that are over the age of 120 that are marked as alive in the Social Security system,” said Steve Davis, who has previously worked alongside Musk at SpaceX, the Boring Company, and X

He explained that despite this being discovered by hardworking personnel at the SSA back in 2008, nothing was done. As a result, 15-20 million social security numbers that were clearly fraudulent were just floating around, susceptible to being used for “bad intentions.”

Health care entrepreneur Brad Smith, who has taken charge of auditing HHS and NIH, also cited stunning, troubling statistics displaying the extreme inefficiencies of the nation’s top federal health organizations.

Smith said that at NIH, “Today they have 27 different centers” created by Congress over the years and there are “700 different IT systems,” each using their own IT software.

“They have 27 different CIOs (Chief Information Officers),” added Smith, “so when you think about making great medical discoveries, you have to connect the data.”  

Those discoveries are likely severely hampered by NIH’s communications disconnect.

Anthony Armstrong, a Morgan Stanley banker now working for DOGE at the Office of Personnel Management (OPM) talked about “duplicative functions” and “overstaffing” at government agencies. He said that money is “sloshing out the door.”

As an example, he cited the IRS, which has 1,400 employees whose only job is to provision laptops and cell phones to IRS workers.  

“As an ex-CFO of a big public tech company, really what we’re doing is, we’re applying public company standards to the federal government, and it is alarming how the financial operations and financial management is set up today,” said Tom Krause, CEO of Cloud Software Group.  

He explained that there is virtually no accountability or verification protections when it comes to the Treasury Department disbursing funds to various government agencies.

A 94-year-old grandmother is no longer “going to be robbed by forces like she’s getting robbed today, and the solvency of the federal government will ensure that she continues to receive those social security checks,” added Musk.

“The reason we’re doing this is because if we don’t do it, America is going to go insolvent and go bankrupt, and nobody’s going to get anything,” said Musk.

Tyler Hassen, a former oil executive working at the Interior Department for DOGE ​​alleged that there was no departmental oversight at the Interior Department “whatsoever” under the Biden administration.  

Steve Davis talked about the out-of-control issuance and use of federal credit cards. 

“There are in the federal government around 4.6 million credit cards for around 2.3 to 2.4 million employees. This doesn’t make sense. So, one of the things all of the teams have worked on is we’ve worked for the agencies and said, ‘Do you need all of these credit cards? Are they being used? Can you tell us physically where they are?’” recounted Davis.

“Clearly there should not be more credit cards than there are people,” interjected Musk.

Musk later described how the Small Business Administration (SBA) has given out $300 million in loans to people “under the age of 11.” An additional $300 million in loans has been handed out to people “over the age of 120.”

Musk said that these government loans are clearly “fraudulent.”  

“Terrible things are being done,” he exclaimed. “We’re stopping it.” 

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