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Crime

Inside America’s Fastest-Growing Criminal Enterprise: Sex Trafficking

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34 minute read

News release from the Free Press

Madeleine Rowley

Biden’s border policies have led to an explosion in the forced prostitution of migrant boys and girls in the U.S. ‘If I wanted to, I could order a girl within 15 minutes. It’s that easy.’

Lisa slides a Hellcat pistol into her backpack, slinging it over her shoulder. She jumps out of the driver’s seat of her massive Ford F-250 as we head into a barbecue joint for lunch. Steel brass knuckles glint in the console beside a pencil-shaped, pronged object. She sees me looking at it.

“That’s my stabby-stick,” Lisa says before I even ask. “In case I can’t bring my gun somewhere. These guys are dangerous.”

“These guys” are sex traffickers, and dangerous doesn’t begin to describe them.

Many traffickers are members of Mexican or Salvadorian gangs, part of Cuban rings or the vicious Venezuelan group Tren de Aragua. Their modus operandi is luring migrant women and girls across the southern border, promising them good jobs once they get to America, and then forcing them into prostitution once they’re here, ostensibly to pay off the debt they incurred to get into the U.S. Hunting down sex traffickers is not for the faint of heart, and Lisa is not about to take any chances.

An athletic, no-nonsense blonde in her 50s, Lisa runs a small nonprofit foundation called Shepherd’s Watch, dedicated to bringing down sex-trafficking rings. Prior to starting Shepherd’s Watch in 2016, Lisa had been a telecom engineer and an expert at analyzing cell phone data used in court cases. In that job, she says, she saw a “disturbing” amount of child exploitation. “I couldn’t ignore it anymore.”

Lisa, who asked that we not use her real name, calls herself “an informant.” She lacks the authority to arrest a trafficker, and any attempt to rescue the girls herself could well get her killed. Instead, Lisa and a small handful of other Shepherd’s Watch investigators work to locate victims and their pimps and then turn the information over to police departments, sheriff’s offices, and other law enforcement agencies. Because Lisa and her team have gained credibility with law enforcement over the years, the police usually follow up on the information the Shepherd’s Watch informants provide. Sometimes they hit pay dirt, arresting the traffickers and removing the girls to a safe place.

“Law enforcement is understaffed and stretched too thin,” says Lisa. “That’s where we come in.”

At the barbecue joint off Route 75 in Dallas, Lisa pulls out her phone to show me the dozen or so online platforms that traffickers and pimps use to sell girls for sex. The platforms—which include apps like TikTokOnlyFans, and Facebook—are chockablock with ads of women, usually wearing lingerie, their faces covered to prevent anyone guessing their age. The sheer number of ads is astonishing. “Each week, we track over 12,000 ads for women in Houston, 2,600 in San Antonio, 3,500 in Austin, and 14,000 in Dallas,” says Lisa.

I ask her if the sex trafficking of migrant girls had increased since the Biden administration threw open the border, leading to 8 million migrants crossing the southern border since 2021. “Yes,” she says. “Nearly all of my sex-trafficking rings now are migrant girls. The ads exploded within the first three months of the border being open. We started noticing new sites and ads in Spanish. That was very few before. Then sites dedicated to Latino girls popped up everywhere.” Since the border opened, Lisa added, over 90 percent of the ads are for migrant girls.

Inside America’s Fastest-Growing Criminal Enterprise: Sex Trafficking
Many traffickers are members of Mexican or Salvadorian gangs, part of Cuban rings or the vicious Venezuelan group Tren de Aragua. (Robert Gauthier via Getty Images)

“If I wanted to, I could order a girl within 15 minutes,” Lisa says. “It’s that easy.”

And she’s right. After lunch, we drive around the seedier areas of the Dallas suburb of Plano. We’re guided by Jack, an intelligence contractor for Shepherd’s Watch who specializes in geospatial analysis. Jack, who also asked to remain anonymous, works from an office in California. Formerly in law enforcement, he tracks phones using the location data in the background of mobile apps, identifies patterns with cell phone numbers, and does tattoo and facial recognition work. Federal agencies often engage him.

Pretending to be a client, Jack texts a woman on a website called Escort13. She is described as a “new Latina in the city.” The woman tells Jack that she’s at Motel 6 off the North Central Expressway in Plano. Like a scene in a spy movie, Jack relays the information from his California office to Lisa in Texas through the truck’s crackling speakers.

In her profile photo, the woman is dressed in a black, long-sleeve, crop top shirt and short black skirt—modest compared to pictures of some of the other girls that Lisa has shown me. Her dark hair hangs straight below her waist, and her phone covers her face, which conceals her age and identity.

Her profile says she’s 24 years old and that her home base is Philadelphia—neither of which is necessarily true. Gang-led trafficking rings tend to move their victims all over the U.S.; it’s one way they try to stay ahead of the law. So it’s no surprise this young woman is now working out of a motel in Texas. According to Lisa, Latin American girls like her go for anywhere from $130 to $160 per half hour.

After Jack makes contact with the woman, he tells Lisa, “She says to take a photo of the motel’s entrance, and then she’ll give me the room number.” Lisa snaps a photo through the windshield and sends it to Jack, who texts it to the woman and gets the room number. It’s on the second floor of the two-story motel. We drive to the far end of the parking lot, where we have a clear view of the balcony.

A Latina girl pokes her head out the door and cautiously looks around. Realizing no one is there, she retreats inside. A few moments later, a shirtless man throws up the shades in the room directly below her and swivels his head to look around the parking lot.

“That’s probably her pimp or a trafficker,” Lisa says. “Time to go.”

We peel out of the lot and drive to a Studio 6 motel two miles down the road, where Jack is communicating with another migrant girl. This motel doesn’t have balconies, and when Jack asks her to come to the lobby, she says no. We have no choice but to drive away.

Still, it’s been a successful afternoon. With Jack’s help, Lisa has found two possibly sex-trafficked women and one likely trafficker. When Lisa picks me up the following day, she’s on the phone with Plano law enforcement recounting what we saw the day before at the Motel 6.

“She looked young to me,” says Lisa.

In a follow-up phone call, Lisa tells me the police went to the motel to check it out, but the girl was gone. They think she was part of a trafficking ring.

“She’ll resurface,” says Lisa. “They always do.”

Inside America’s Fastest-Growing Criminal Enterprise: Sex Trafficking
Gangs lure migrant women across the border with the promise of good jobs, and then force them into prostitution once they arrive. (Illustration by The Free Press, image via Getty)

Deep inside the U.S. Department of Health and Human Services resides a tiny agency called the Office on Trafficking in Persons. A large part of its mission is to help survivors of sex and labor trafficking “rebuild their lives and become self-sufficient.” Among other things, it offers food assistance, medical benefits, and cash to migrant minors who have been trafficked but have managed to escape. Once their eligibility to obtain benefits is approved, they receive a document called the child eligibility letter.

Although the number of child eligibility letters the government issues is supposed to be public information, it became available on the trafficking office’s website only after I filed a Freedom of Information Act request. The numbers confirmed what Lisa had told me: Trafficking has increased—a lot—since Biden took office. During the four years of the Trump administration, the government issued an average of 625 letters per year to migrant minors who had managed to break free from their traffickers.

But in 2021, the first year of the Biden administration, that number jumped to 1,143. In 2022 it jumped again, to 2,226. Last year, the number stood at 2,148, but that was only through September; the fourth quarter hadn’t yet been counted. To put it another way, forced labor and prostitution among underage migrants more than tripled under President Biden, reaching record highs. And that only counted the handful who had escaped—not the thousands who were still held by the traffickers, the ones Lisa was searching for.

“The sex trafficking of minors, and human trafficking as a whole, is one of the fastest-growing criminal enterprises in the U.S.,” said Homeland Security Investigations Special Agent in Charge Mark Dawson after a big bust in Houston last year that saw the arrest of 10 traffickers, all of whom had gang connections.

Sex-trafficking victims often suffer horrific abuse, as I discovered when I spoke to Landon Dickeson, the 36-year-old executive director for Bob’s House of Hope in Denton, Texas, the only shelter for male sex-trafficking victims ages 18 and up in the country. Dickeson says they’ve seen teens from Central and South America who have been so tortured by their traffickers they can barely function.

Dickeson described caring for teens who have brain damage from being so heavily drugged—teens who have had their fingernails pulled out, and lemon juice poured on wounds. When I asked to interview one of their migrant residents, Dickeson said they simply weren’t in any condition to speak to anyone, much less a reporter.

“We think the cartels and gangs use torture as a control method for the males,” said Dickeson. “They’re not going to fight back if they chain their victims to a radiator, beat them up frequently, or drug them.”

The House of Hope residents often come branded or tattooed by the cartels and gangs who trafficked them, and most were cross-victimized—used as drug mules as well as for labor and sex.

Bob Williams, CEO and founder of Bob’s House of Hope, says they receive two to three calls a month to help minor males who have been sex trafficked. “There is not one shelter in the country for 12- to 17-year-olds,” he said. “This is a big problem because they get put in the system and don’t get the help they need.” Williams, who was sexually assaulted as a teen himself, says they’re working on procuring more funding to build a program for minors.

There is no question that the border crisis is the primary reason for the increase in the sex trafficking of migrants. Here’s how it works: When underage migrants cross the border unaccompanied by a family member, they are sent to a temporary holding facility run by one of a number of nonprofit organizations operating at the border. The NGOs are expected to move the migrants out within a couple of weeks because there are so many more coming in right behind them. During the time the migrants are in the holding facility, both the NGOs and the government are supposed to vet the people who will take them when they depart. These people are called sponsors, and the vast preference of everyone in the system is that they be relatives already living in the U.S.

But sometimes an underage migrant doesn’t have a family sponsor, which gives the cartels and gangs their opening. They pretend to be legitimate sponsors, and with the pressure on the NGOs and the government to move the migrants through the system quickly, gang members—who usually have their hooks into the migrant well before they’ve crossed the border—are accepted as sponsors.

How do they get away with this? They fill out applications in illegible handwriting, guessing (often correctly) that no one will look at it closely. They coach the girl or boy to say that their sponsor is a cousin or an uncle. And they take advantage of the fact that the federal agency overseeing migrant relocation, the Office of Refugee Resettlement—or ORR—is notoriously negligent in vetting sponsors.

For instance, the ORR is supposed to send fingerprints of nonfamily sponsors to the FBI to see if they have a criminal record, and to do background checks for child abuse or neglect. But earlier this year, the Department of Health and Human Services’ inspector general conducted a study of 343 randomly chosen minors to see if their sponsors had been vetted properly. Their findings, issued in February, concluded that 19 percent of the children were released to sponsors before the fingerprint and background checks were completed—meaning that criminals could well have taken migrant children without the government realizing it.

In July, Republican senator Chuck Grassley hosted a roundtable on the trafficking crisis at the border. Tara Rodas, 55, a federal employee who in 2021 worked at an emergency intake shelter in California, testified that while she was there, a 13-year-old girl from El Salvador was released to a sponsor in Ohio who was affiliated with the MS-13 gang.

In an email Rodas sent to a colleague at the time, which was released by Grassley, she wrote that “our team discovered that human traffickers are exploiting the HHS Unaccompanied Children. ‘Bad actors’ are recruiting, harboring, and transporting minors; using force, fraud, and coercion; for the purpose of involuntary servitude, debt bondage, slavery, and potentially commercial sex.”

Inside America’s Fastest-Growing Criminal Enterprise: Sex Trafficking
Migrants camping in the border area of Jacumba, California. (Katie McTiernan via Getty Images)

Deborah White, another whistleblower who worked at the same shelter, testified that migrant children were handed over to improperly vetted sponsors who used fraudulent IDs and different addresses to procure numerous unrelated children. “I had multiple cases that I reported on,” said White, meaning she reported suspicious sponsors to her supervisor. “One in particular where we sent 329 children to one address: two garden apartment [buildings] in Houston, Texas.” The supervisor, White told The Free Press in an interview, took no steps to investigate further, but instead told White that she wasn’t moving migrants out of the facility quickly enough.

Washington’s lack of interest in the sex-trafficking crisis is stunning. Sometimes it seems as though the only person in a position of power who cares about the issue is 91-year-old Senator Grassley. And he has been as passionate about it when Trump was president as he is now, during Biden’s presidency.

“I’ve been trying to protect unaccompanied children that are put in dangerous environments,” he told me in an interview. “These are the most vulnerable people, and somebody’s got to look out for them, and that’s me.”

As far back as 2014, when “just” 57,000 unaccompanied children crossed the border—less than half the current number—Grassley sounded the alarm that the Office of Refugee Resettlement was having trouble accommodating so many migrant children.

The next year, he wrote a letter to the Department of Homeland Security, saying that up to 3,400 unaccompanied children’s sponsors had criminal histories. Two years later, he urged the ORR to take responsibility for unaccompanied children who had ties to the gang. “Your agencies repeatedly pass the buck to each other. As a result, children are allowed to disappear. When these children disappear without any supervision, they are vulnerable to join dangerous gangs like MS-13,” he said.

Grassley reached across the aisle in 2019 and 2021, working with Democratic senators Dianne Feinstein and Ron Wyden, respectively, regarding allegations of sexual abuse and employee misconduct at ORR-funded shelters. Grassley and Wyden’s investigation found that between 2016 and 2020, ORR received nearly 7,500 reports of sexual misconduct involving an unaccompanied child staying at a shelter. Wyden attributed this to “years of mismanagement and poor oversight” by ORR.

With the election of Joe Biden—and the border crisis that ensued—other Republicans have jumped on the trafficking bandwagon, but Grassley has continued to lead the charge, using his staff to conduct significant investigations. In January, for instance, he sent a detailed letter to Department of Homeland Security Secretary Alejandro Mayorkas and FBI Director Christopher Wray, detailing evidence his staff had uncovered of unaccompanied children who were suspected of being in the hands of traffickers.

Democrats have been shamefully silent on the trafficking issue. At the roundtable Grassley held in July, not a single Democrat attended. Neither did Mayorkas. “Democrats didn’t come because they’re just too embarrassed to talk about the shortcomings of this administration on immigration,” Grassley told me. “Especially when you have HHS sending kids to MS-13 gang-related sponsors in Ohio. It’s hard to explain that.”

As for the Office of Refugee Resettlement, its track record remains abysmal. It has yet to do anything to reduce the sex trafficking that is taking place under its nose. On the contrary, it has lately been pushing through rules that will minimize the vetting of sponsors—for instance, making background checks optional instead of mandatory. This, of course, will allow the NGOs to push migrant children through the system even faster. But it will also make it easier for gangs and criminals to “sponsor” migrant girls after they’ve crossed the border. Grassley is trying to stop that from happening, but with the Democrats in control of the Senate, it’s an uphill fight.

That gangs are sex trafficking women and girls who cross the border—and that the Office of Refugee Resettlement is making it so easy for them—is an open secret to everyone who is part of the system. One proof point: An NGO operating at the border, the U.S. Committee for Refugees and Immigrants, started a program in 2022 specifically aimed at helping trafficked kids. Naturally, it is paid for by the Biden administration. Indeed, like all the NGOs at the border, the organization gets well over 95 percent of its revenue from the Office of Refugee Resettlement, in its case $292 million. Of that amount, $60 million goes to caring for unaccompanied children, including trafficked children, according to its 2023 federal filing.

The initiative for trafficked migrants is called the Aspire program. Aspire uses subcontractors to connect migrant children with immigration lawyers, food, clothing, and medical services. It also helps them get child eligibility letters so they’ll qualify for cash, which ranges from about $1,000 to $6,000, depending on the child’s needs and where they live.

Leah Breevoort, a supervisor for the U.S. Committee for Refugees and Immigrants trafficking services department, told me that most of the children whose cases they manage represent the most extreme cases of trafficking. The Aspire program currently has 767 migrants, all of whom have child eligibility letters. Rather matter-of-factly, she said she had seen cases in which the sponsor was trafficking a child, or when “the child has a debt from their travel journey, and therefore are working to pay off that debt.”

Once the children are released from the temporary shelters, they’re no longer the federal government’s responsibility, so even kids with child eligibility letters wind up having to fend for themselves. “We try to find a safe placement for that minor,” said Breevoort. “Sometimes it’s a homeless runaway shelter or another migrant shelter. But it’s really, really difficult.”

Immigration lawyer Emma Hetherington, the director of the Wilbanks Child Endangerment and Sexual Exploitation (CEASE) Clinic at the University of Georgia School of Law, also confirmed that some of the migrant children she’s worked with were sex trafficked by their sponsors or by another adult living in the same home.

At CEASE, Hetherington has seen an overlap with migrant children who were trafficked for both labor and sex. “This is a very vulnerable population,” she said. “They’re easier to manipulate because their basic needs aren’t being met. These kids did not and cannot consent to being trafficked.”

Inside America’s Fastest-Growing Criminal Enterprise: Sex Trafficking
A California Border Patrol agent processes migrants after they crossed into the U.S. from Mexico near Jacumba, California. (Qian Weizhong via Getty Images)

With the federal government mostly looking the other way, it falls to people like Lisa and local law enforcement to bust up sex-trafficking rings. And there have been some success stories.

In March, the Indianapolis Metropolitan Police Department rescued a teen girl and four other women who were being held in a house in the suburbs near a golf course by a sex-trafficking ring run by the Venezuelan gang Tren de Aragua.

In April, police in Socorro, Texas, near El Paso, raided a house where seven young girls were being sex trafficked. “We’re here to rescue those that otherwise might not have a voice,” said Chief David Burton at the time.

In May, the East Baton Rouge Parish Sheriff’s Office in Louisiana busted a sex-trafficking ring run by Tren de Aragua. There were up to 30 victims who were allegedly stashed in homes throughout Virginia, Louisiana, Texas, and Florida.

In August, the San Antonio Police Department, aided by Homeland Security, arrested two Venezuelan illegal immigrants for sex trafficking two women. The alleged traffickers forced the women to work up to 20 hours a day providing sexual services, under the threat of violence. The suspected traffickers took 60 percent of the money.

One law enforcement official who has focused on sex trafficking is Sheriff Grady Judd of Polk County, Florida. His experience is proof that something can be done about trafficking if law enforcement makes it a priority. The Polk County Sheriff’s Department frequently conducts operations in which, like Lisa and Jack, investigators pose online as clients to locate potential victims.

Their largest bust to date, which took place last March, yielded 228 arrests, with 13 potential trafficking victims rescued—10 of whom were migrants.

Although most of those arrested were “johns,” Judd’s office also nabbed several dozen traffickers, most of whom were illegal immigrants from Chile, Cuba, Guatemala, Mexico, Peru, and Venezuela. Since the bust, trafficking in Polk County has decreased, Judd told me.

“Traffickers think, ‘We’re not going to Polk County. We know what happened there. That sheriff don’t play,’ ” Judd said.

In many of my interviews, people told me that trafficking has become so widespread that I could find it anywhere in the country. I was skeptical about these claims, but Lisa wasn’t.

“I’ll show you,” she says one morning after filling her tank with gas. She pulls up a website on her phone—its tagline is “Where Fantasy Meets Reality”—and clicks on the profile of a foot spa in Dallas. In the description, the masseuse is described as “Asian, Chinese,” and it’s cash only, with a 60-minute massage priced at $60.

We drive into a strip mall and park in front of the foot spa. The business’s windows are tinted, making it impossible to see inside. There’s a hair salon next door, and a mother holds her toddler’s hand as they walk toward an adjacent grocery store. We watch as men enter and exit the spa.

We decide to enter ourselves, and the first thing I see are five security cameras trained on us. The front desk is unmanned, and there’s a small waiting area with a couch to the left. After a few minutes, a woman slowly opens a door that separates the front entryway from the massage area. Her bright pink silk robe hangs open, revealing black lingerie underneath.

“Do you have gift cards?” Lisa asks—pretending she wants to buy one for a male friend.

The woman looks confused and shakes her head, shooting us a furtive glance before closing the door.

Back in the truck, Lisa explains that there are sex-trafficking rings being run out of illicit massage parlors—basically brothels—all over the country.

After I return to my home near Baltimore, Maryland, I go online to see if there are any illicit massage parlors and foot spas near me.

I found one two miles away.

Madeleine Rowley is an investigative reporter. Follow her on X @Maddie_Rowley, and read her piece “Nonprofits Are Making Billions off the Border Crisis.”

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

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Sam Cooper's avatar Sam Cooper

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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Closing information gaps to strengthen Canada’s border security and track fentanyl

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Macdonald-Laurier Institute

By Sean Parker, Dawn Jutla, and Peter Copeland for Inside Policy

To promote better results, we lay out a collaborative approach

Despite exaggerated claims about how much fentanyl is trafficked across the border from Canada to the United States, the reality is that our detection, search, and seizure capacity is extremely limited.

We’re dealing with a “known unknown”: a risk we’re aware of, but don’t yet have the capacity to understand its extent.

What’s more, it may be that the flow of precursor chemicals—ingredients used in the production of fentanyl—is where much of the concern lies. Until we enhance our tracking, search, and seizure capacity, much will remain speculative.

As border security is further scrutinized, and the extent of fentanyl production and trafficking gets brought into sharper focus, the role of the federal government’s Precursor Chemical Risk Management Unit (PCRMU)—announced recently by Health Canada—will become apparent.

Ottawa recently took action to enhance the capabilities of the PCRMU. It says the new unit will “provide better insights into precursor chemicals, distribution channels, and enhanced monitoring and surveillance to enable timely law enforcement action.” The big question is, how will the PCRMU track the precursor drugs entering into Canada that are used to produce fentanyl?

Key players in the import-export ecosystem do not have the right regulatory framework and responsibilities to track and share information, detect suspect activities, and be incentivized to act on it. That’s one of the reasons why we know so little about how much fentanyl is produced and trafficked.

Without proper collaboration with industry, law enforcement, and financial institutions, these tracking efforts are doomed to fail. To promote better results, we lay out a collaborative approach that distributes responsibilities and retools incentives. These measures would enhance information collection capabilities, incentivize system actors to compliance, and better equip law enforcement and border security services for the safety of Canadians.

Trade-off bottleneck: addressing the costs of enhanced screening

To date, it’s been challenging to increase our ability to detect, search, and seize illegal goods trafficked through ports and border crossings. This is due to trade-offs between heightened manual search and seizure efforts at ports of entry, and the economic impacts of these efforts.

In 2024, the Canada Border Services Agency (CBSA) admitted over 93 million travelers. Meanwhile, 5.3 million trucks transported commercial goods into Canada, around 3.6 million shipments arrived via air cargo, nearly 2 million containers were processed at Canadian ports, roughly 1.9 million rail cars carried goods into the country, and about 145.7 million courier shipments crossed the border. The CBSA employs a risk-based approach to border security, utilizing intelligence, behavioral analysis, and random selection to identify individuals or shipments that may warrant additional scrutiny. This triaging process aims to balance effective enforcement with the facilitation of legitimate travel and trade.

Exact percentages of travelers subjected to secondary inspections are not publicly disclosed, but it’s understood that only a small fraction undergo such scrutiny. We don’t learn about the prevalence of these issues through our border screening measures, but in crime reporting data—after it’s too late to avert.

It’s key to have an approach that minimizes time and personnel resources deployed at points of entry. To be effective without being economically disruptive, policymakers, law enforcement, and border security need to strengthen requirements for information gathering, live tracking, and sharing. Legislative and regulatory change to require additional information of buyers and sellers—along with stringent penalties to enforce non-compliance—is a low-cost, logistically efficient way of distributing responsibility for this complex and multifaceted issue. A key concept explored in this paper is strengthening governance controls (“controls”) over fentanyl supply chains through new processes and data digitization, which could aid the PCRMU in their strategic objectives.

Enhanced supply chain controls are needed

When it comes to detailed supply chain knowledge of fentanyl precursor chemicals moving in and out of Canada, regulator knowledge is limited.

That’s why regulatory reform is the backbone of change. It’s necessary to ensure that strategic objectives are met by all accountable stakeholders to protect the supply chain and identify issues. To rectify the issues, solutions can be taken by the PCRMU to obtain and govern a modern fentanyl traceability system/platform (“platform”) that would provide live transparency to regulators.   

A fresh set of supply chain controls, integrated into a platform as shown in Fig. 1, could significantly aid the PCRMU in identifying suspicious activities and prioritizing investigations.

Fig. 1. Canadian purchasers and transporters would authenticate packaging, documentation, and contents for shipments of fentanyl and its precursor chemicals in a live tracking system. They would provide  transparency into shipments, and share discrepancies, payment intermediaries, and payment recipients with regulators. Banks would share payment information for fentanyl shipments with regulators. Figure provided by the authors.

Our described system has two distinctive streams: one which leverages a combination of physical controls such as package tampering and altered documentation against a second stream that looks at payment counterparties. Customs agencies, transporters, receivers, and financial institutions would have a hand in ensuring that controls in the platform are working. The platform includes several embedded controls to enhance supply chain oversight. It uses commercially available Vision AI to assess packaging and blockchain cryptography to verify shipment documentation integrity. Shipment weight and quantity are tracked from source to destination to detect diversion, while a four-eyes verification process ensures independent reconciliation by the seller, customs, and receiver. Additionally, payment details are linked to shipments to uncover suspicious financial activity and support investigations by financial institutions and regulators like FINTRAC and FINCEN.

A modern platform securely distributes responsibility in a way that’s cost effective and efficient so as not to overburden any one actor. It also ensures that companies of all sizes can participate, and protects them from exploitation by criminals and reputational damage.

In addition to these technological enhancements and more robust system controls, better collaboration between the key players in the fentanyl supply chain is needed, along with policy changes to incentivize each key fentanyl supply chain stakeholder to adopt the new controls.

Canadian financial institutions: a chance for further scrutiny

Financial institutions (FIs) are usually the first point of contact when a payment is being made by a purchaser to a supplier for precursor chemicals that could be used in the production of fentanyl. It is crucial that they enhance their screening and security processes.

Chemicals may be purchased by wires or via import letters of credit. The latter is the more likely of the two instruments to be used because this ensures that the terms and conditions in the letter of credit are met with proof of shipment prior to payment being released.  Payments via wire require less transparency.

Where a buyer pays for precursor chemicals with a wire, it should result in further scrutiny by the financial institution. Requests for supporting documentation including terms and conditions, along with proof of shipment and receipt, should be provided. Under new regulatory policy, buyers would be required to place such supporting documentation on the shared platform.

The less transparent a payment channel is in relation to the supply chain, the more concerning it should be from a risk point of view. Certain payment channels may be leveraged to further mask illicit activity throughout the supply chain. At the onset of the relationship the seller and buyers would link payment information on the platform (payment channel, recipient name, recipient’s bank, date, and payment amount) to each precursor or fentanyl shipment. The supplier, in turn, should record match payment information (payment channel, supplier name, supplier’s bank, date, and payment amount).

Linking payment to physical shipment would enable data analytics to detect irregularities. An irregularity is flagged when the amounts and/or volume of payments far exceed the value of the received goods or vice versa. The system would be able to understand which fentanyl supply chains tend to use a particular set of FIs. This makes it possible to conduct real-time mapping of companies, their fentanyl and precursor shipments and receipts, and the payment institutions they use. With this bigger picture, FIs and law enforcement could connect the dots faster.

Live traceability reporting

Today, suppliers of fentanyl precursors are subject to the Pre-Export Notification Online (PEN Online) database. This database enables governments to monitor international trade in precursor chemicals by sending and receiving pre-export notifications. The system helps prevent the diversion of chemicals used in the illicit manufacture of drugs by allowing authorities to verify the legitimacy of shipments before they occur.

​To further strengthen oversight, the platform utilizes immutability technologies—such as blockchain or secure immutable databases—which can be employed to encrypt all shipping documents and securely share them. This presents an auditable form of chain-of-custody and makes any alterations apparent. Customs and buyers would have the capability to verify the authenticity of the originating documents in a way that doesn’t compromise business confidentiality. With the use of these technologies, law enforcement can narrow down their investigations.

An information gap currently exists as the receivers of the shipments don’t share their receipts information with PEN. To strengthen governance on fentanyl supply chains, regulatory policy and legislative changes are needed. The private sector should be mandated to report received quantities of fentanyl or its precursors, as well as suspicious receiving destinations. This could be accomplished on the platform which would embed the receiving process, a reconciliation process of the transaction, the secure upload and sharing of documents, and would be minimally disruptive to business processes.

Additionally, geo-location technology embedded in mobile devices and/or shipments would provide real-time location-based tracking of custody transactions. These geo-controls would ensure accountability across the fentanyl supply chain, in particular where shipments veer off or stop too long on regular shipping routes. Canadian transporters of fentanyl and its precursor chemicals should play an important role in detecting illicit diversion/activities.

Digital labelling

Licensed fentanyl manufacturers could add new unique digital labels to their shipments to get expedited clearance. For example, immutable digital labelling platforms enable tamper-proof digital labels for legitimate fentanyl shipments. This would give pharmacies, doctors, and regulators transparency into the fentanyl’s:

  • Chemical composition and concentrations (determining legitimate vs. adulterated versions of the drug)
  • Manufacturing facility ID, batch ID, and regulatory compliance status
  • Intended buyer authentication (such as licensed pharmaceutical firms or distributors)

Immutable digital labelling platforms offer secure role-based access control. They can display customized data views according to time of day, language, and location. Digital labels could enable international border agencies and law enforcement to receive usable data, allowing legal shipments through faster while triggering closer shipment examinations for those without of a digital label.

International and domestic transporter controls

Transporters act as intermediaries in the supply chain. Their operations could be monitored through a regulatory policy that mandates their participation in the platform for fentanyl and precursor shipments. The platform would support a mobile app interface for participants on-the-move, as well as a web portal and application programming interfaces (APIs) for large-size supply chain participants. Secure scanning of packaging at multiple checkpoints, combined with real-time tracking, would provide an additional layer of protection against fraud, truckers taking bribes, and unauthorized alterations to shipments and documents.

Regulators and law enforcement participation

Technology-based fentanyl controls for suppliers, buyers, and transporters may be reinforced by international customs and law enforcement collaboration on the platform. Both CBSA and law enforcement could log in and view alerts about suspicious activities issued from the FIs, transporters, or receivers. The reporting would allow government personnel to view a breakdown of fentanyl importers, the number of import permit applications, and the amount of fentanyl and its precursors flowing into the country. Responsible regulatory agencies—such as the CBSA and PCRMU—could leverage the reporting to identify hot spots.

The platform would use machine learning to support CBSA personnel in processing an incoming fentanyl or precursor shipment. Machine learning refers to AI algorithms and systems that improve their knowledge with experience. For example, an AI assistant on the traceability system could use machine learning to predict and communicate which import shipments arriving at the border should be passed. It can base these suggestions on criteria like volume, price, origin of raw materials, and origin of material at import point. It can also leverage data from other sources such as buyers, sellers, and banks to make predictions. As an outcome, the shipment may be recommended to pass, flagged as suspicious, or deemed to require an investigation by CBSA.

It’s necessary to keep up to date on new precursor chemicals as the drug is reformulated. Here, Health Canada can play a role, using its new labs and tests—expected as part of the recently announced Canadian Drug Analysis Centre—to provide chemical analysis of seized fentanyl. This would inform which additional chemical supply chains should be tracked in the PCRMU’s collaborative platform, and all stakeholders would widen their scope of review.

These new tools would complement existing cross-border initiatives, including joint U.S.-Canada and U.S.-Mexico crackdowns on illicit drug labs, as well as sovereign efforts. They have the potential to play a vital role in addressing fentanyl trafficking.

A robust, multi-pronged strategy—integrating existing safeguards with a new PCRMU traceability platform—could significantly disrupt the illegal production and distribution of fentanyl. By tracking critical supply chain events and authenticating shipment data, the platform would equip law enforcement and border agencies in Canada, the U.S., and Mexico with timely, actionable intelligence. The human toll demands urgency: from 2017 to 2022, the U.S. averaged 80,000 opioid-related deaths annually, while Canada saw roughly 5,500 per year from 2016 to 2024. In just the first nine months of 2024, Canadian emergency services responded to 28,813 opioid-related overdoses.

Combating this crisis requires more than enforcement. It demands enforceable transparency. Strengthened governance—powered by advanced traceability technology and coordinated public-private collaboration—is essential. This paper outlines key digital controls that can be implemented by global suppliers, Canadian buyers, transporters, customs, and financial institutions. With federal leadership, Canada can spearhead the adoption of proven, homegrown technologies to secure fentanyl supply chains and save lives.


Sean Parker is a compliance leader with well over a decade of experience in financial crime compliance, and a contributor to the Macdonald-Laurier Institute.

Dawn Jutla is the CEO of Peer Ledger, the maker of a traceability platform that embeds new control processes on supply chains, and a professor at the Sobey School of Business.

Peter Copeland is deputy director of domestic policy at the Macdonald-Laurier Institute.

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