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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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China, Mexico, Canada Flagged in $1.4 Billion Fentanyl Trade by U.S. Financial Watchdog

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The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) has identified $1.4 billion in fentanyl-linked suspicious transactions, naming China, Mexico, Canada, and India as key foreign touchpoints in the global production and laundering network. The analysis, based on 1,246 Bank Secrecy Act filings submitted in 2024, tracks financial activity spanning chemical purchases, trafficking logistics, and international money laundering operations.

The data reveals that Mexico and the People’s Republic of China were the two most frequently named foreign jurisdictions in financial intelligence gathered by FinCEN. Most of the flagged transactions originated in U.S. cities, the report notes, due to the “domestic nature” of Bank Secrecy Act data collection. Among foreign jurisdictions, Mexico, China, Hong Kong, and Canada were cited most often in fentanyl-related financial activity.

The FinCEN report points to Mexico as the epicenter of illicit fentanyl production, with Mexican cartels importing precursor chemicals from China and laundering proceeds through complex financial routes involving U.S., Canadian, and Hong Kong-based actors.

The findings also align with testimony from U.S. and Canadian law enforcement veterans who have told The Bureau that Chinese state-linked actors sit atop a decentralized but industrialized global fentanyl economy—supplying precursors, pill presses, and financing tools that rely on trade-based money laundering and professional money brokers operating across North America.

“Filers also identified PRC-based subjects in reported money laundering activity, including suspected trade-based money laundering schemes that leveraged the Chinese export sector,” the report says.

A point emphasized by Canadian and U.S. experts—including former U.S. State Department investigator Dr. David Asher—that professional Chinese money laundering networks operating in North America are significantly commanded by Chinese Communist Party–linked Triad bosses based in Ontario and British Columbia—is not explored in detail in this particular FinCEN report.¹

Chinese chemical manufacturers—primarily based in Guangdong, Zhejiang, and Hebei provinces—were repeatedly cited for selling fentanyl precursors via wire transfers and money service businesses. These sales were often facilitated through e-commerce platforms, suggesting that China’s global retail footprint conceals a lethal underground market—one that ultimately fuels a North American public health crisis. In many cases, the logistics were sophisticated: some Chinese companies even offered delivery guarantees and customs clearance for precursor shipments, raising red flags for enforcement officials.

While China’s industrial base dominates the global fentanyl supply chain, Mexican cartels are the next most prominent state-like actors in the ecosystem—but the report emphasizes that Canada and India are rising contributors.

“Subjects in other foreign countries—including Canada, the Dominican Republic, and India—highlight the presence of alternative suppliers of precursor chemicals and fentanyl,” the report says.

“Canada-based subjects were primarily identified by Bank Secrecy Act filers due to their suspected involvement in drug trafficking organizations allegedly sourcing fentanyl and other drugs from traditional drug source countries, such as Mexico,” it explains, adding that banking intelligence “identified activity indicative of Canada-based individuals and companies purchasing precursor chemicals and laboratory equipment that may be related to the synthesis of fentanyl in Canada. Canada-based subjects were primarily reported with addresses in the provinces of British Columbia and Ontario.”

FinCEN also flagged activity from Hong Kong-based shell companies—often subsidiaries or intermediaries for Chinese chemical exporters. These entities were used to obscure the PRC’s role in transactions and to move funds through U.S.-linked bank corridors.

Breaking down the fascinating and deadly world of Chinese underground banking used to move fentanyl profits from American cities back to producers, the report explains how Chinese nationals in North America are quietly enlisted to move large volumes of cash across borders—without ever triggering traditional wire transfers.

These networks, formally known as Chinese Money Laundering Organizations (CMLOs), operate within a global underground banking system that uses “mirror transfers.” In this system, a Chinese citizen with renminbi in China pays a local broker, while the U.S. dollar equivalent is handed over—often in cash—to a recipient in cities like Los Angeles or New York who may have no connection to the original Chinese depositor aside from their role in the laundering network. The renminbi, meanwhile, is used inside China to purchase goods such as electronics, which are then exported to Mexico and delivered to cartel-linked recipients.

FinCEN reports that US-based money couriers—often Chinese visa holders—were observed depositing large amounts of cash into bank accounts linked to everyday storefront businesses, including nail salons and restaurants. Some of the cash was then used to purchase cashier’s checks, a common method used to obscure the origin and destination of the funds. To banks, the activity might initially appear consistent with a legitimate business. However, modern AI-powered transaction monitoring systems are increasingly capable of flagging unusual patterns—such as small businesses conducting large or repetitive transfers that appear disproportionate to their stated operations.

On the Mexican side, nearly one-third of reports named subjects located in Sinaloa and Jalisco, regions long controlled by the Sinaloa Cartel and Cartel Jalisco Nueva Generación. Individuals in these states were often cited as recipients of wire transfers from U.S.-based senders suspected of repatriating drug proceeds. Others were flagged as originators of payments to Chinese chemical suppliers, raising alarms about front companies and brokers operating under false pretenses.

The report outlines multiple cases where Mexican chemical brokers used generic payment descriptions such as “goods” or “services” to mask wire transfers to China. Some of these transactions passed through U.S.-based intermediaries, including firms owned by Chinese nationals. These shell companies were often registered in unrelated sectors—like marketing, construction, or hardware—and exhibited red flags such as long dormancy followed by sudden spikes in large transactions.

Within the United States, California, Florida, and New York were most commonly identified in fentanyl-related financial filings. These locations serve as key hubs for distribution and as collection points for laundering proceeds. Cash deposits and peer-to-peer payment platforms were the most cited methods for fentanyl-linked transactions, appearing in 54 percent and 51 percent of filings, respectively.

A significant number of flagged transactions included slang terms and emojis—such as “blues,” “ills,” or blue dots—in memo fields. Structured cash deposits were commonly made across multiple branches or ATMs, often linked to otherwise legitimate businesses such as restaurants, salons, and trucking firms.

FinCEN also tracked a growing number of trade-based laundering schemes, in which proceeds from fentanyl sales were used to buy electronics and vaping devices. In one case, U.S.-based companies owned by Chinese nationals made outbound payments to Chinese manufacturers, using funds pooled from retail accounts and shell companies. These goods were then shipped to Mexico, closing the laundering loop.

Another key laundering method involved cryptocurrency. Nearly 10 percent of all fentanyl-related reports involved virtual currency, with Bitcoin the most commonly cited, followed by Ethereum and Litecoin. FinCEN flagged twenty darknet marketplaces as suspected hubs for fentanyl distribution and cited failures by some digital asset platforms to catch red-flag activity.

Overall, FinCEN warns that fentanyl-linked funds continue to enter the U.S. financial system through loosely regulated or poorly monitored channels, even as law enforcement ramps up enforcement. The Drug Enforcement Administration reported seizures of over 55 million counterfeit fentanyl pills in 2024 alone.

The broader pattern is unmistakable: precursor chemicals flow from China, manufacturing occurs in Mexico, Canada plays an increasing role in chemical acquisition and potential synthesis, and drugs and proceeds flood into the United States, supported by global financial tools and trade structures. The same infrastructure that enables lawful commerce is being manipulated to sustain the deadliest synthetic drug crisis in modern history.

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2025 Federal Election

Canada drops retaliatory tariffs on automakers, pauses other tariffs

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Quick Hit:

Canada has announced it will roll back retaliatory tariffs on automakers and pause several other tariff measures aimed at the United States. The move, unveiled by Finance Minister François-Philippe Champagne, is designed to give Canadian manufacturers breathing room to adjust their supply chains and reduce reliance on American imports.

Key Details:

  • Canada will suspend 25% tariffs on U.S. vehicles for automakers that maintain production, employment, and investment in Canada.
  • A broader six-month pause on tariffs for other U.S. imports is intended to help Canadian sectors transition to domestic sourcing.
  • A new loan facility will support large Canadian companies that were financially stable before the tariffs but are now struggling.

Diving Deeper:

Ottawa is shifting its approach to the escalating trade war with Washington, softening its economic blows in a calculated effort to stabilize domestic manufacturing. On Tuesday, Finance Minister François-Philippe Champagne outlined a new set of trade policies that provide conditional relief from retaliatory tariffs that have been in place since March. Automakers, the hardest-hit sector, will now be eligible to import U.S. vehicles duty-free—provided they continue to meet criteria that include ongoing production and investment in Canada.

“From day one, the government has reacted with strength and determination to the unjust tariffs imposed by the United States on Canadian goods,” Champagne stated. “We’re giving Canadian companies and entities more time to adjust their supply chains and become less dependent on U.S. suppliers.”

The tariff battle, which escalated in April with Canada slapping a 25% tax on U.S.-imported vehicles, had caused severe anxiety within Canada’s auto industry. John D’Agnolo, president of Unifor Local 200, which represents Ford employees in Windsor, warned the BBC the situation “has created havoc” and could trigger a recession.

Speculation about a possible Honda factory relocation to the U.S. only added to the unrest. But Ontario Premier Doug Ford and federal officials were quick to tamp down the rumors. Honda Canada affirmed its commitment to Canadian operations, saying its Alliston facility “will operate at full capacity for the foreseeable future.”

Prime Minister Mark Carney reinforced the message that the relief isn’t unconditional. “Our counter-tariffs won’t apply if they (automakers) continue to produce, continue to employ, continue to invest in Canada,” he said during a campaign event. “If they don’t, they will get 25% tariffs on what they are importing into Canada.”

Beyond the auto sector, Champagne introduced a six-month tariff reprieve on other U.S. imports, granting time for industries to explore domestic alternatives. He also rolled out a “Large Enterprise Tariff Loan Facility” to support big businesses that were financially sound prior to the tariff regime but have since been strained.

While Canada has shown willingness to ease its retaliatory measures, there’s no indication yet that the U.S. under President Donald Trump will reciprocate. Nevertheless, Ottawa signaled its openness to further steps to protect Canadian businesses and workers, noting that “additional measures will be brought forward, as needed.”

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