Finishing up on a week in Canada wouldn’t be right without also publishing a 2 page Canadian Financial Crime Country Dashboard by FCN for September 2023. 

Overall Canada has a strong framework to fight ML/TF. Very high threats come from capital markets fraud, commercial (trade) fraud, bribery and corruption, drug trafficking, illegal gambling, mass marketing fraud, mortgage fraud and 3rd party money laundering. High threats were from currency counterfeiting, piracy of goods, human smuggling, human trafficking, identity fraud, payment card fraud, robbery and theft, tax evasion and tax fraud, tobacco smuggling and trafficking and pollution crime. Medium threats include wildlife crime. 

Terrorism remains a leading threat and Canada has listed 113 terrorist entities that pose a threat, albeit not necessarily a terrorist financing threat. Combating terrorism, including its financing at home and abroad remains a key priority of the Canadian Government.

Canada has identified 33 economic sectors and financial products that present inherent AML vulnerabilities with those rated as “Very High” being Alternative Remittance MSBs, Corporations & Express Trusts (to conceal BO), Domestic Banks, Retail Multi Service MSBs & 18 rated “High” risk including Dealers in Precious Metals and Stones. 

Room for improvement against the 11 FATF Effectiveness criteria is clear with 1/11 lowest rating on IO5 Transparency of BO and 5 with the second lowest ratings including on IO6 Financial Intelligence, IO7 ML Investigations and IO8 ML Confiscations. Recent results in these areas have also shown declines over the last decade, though the recent confiscations of Russian related assets following the illegal invasion of Russia proves more can be done and achieved. 

Highlights include the numerous tactical PPP initiatives on areas such as HT (Project Protect) and wildlife trafficking (Project Anton), led by Canada’s FIU FINTRAC and main Canadian Banks as well as other 3rd parties.

A public consultation on how to improve the Canadian AML/TF system was opened earlier this year in order to find solutions to comprehensively address remaining areas to improve effectiveness. See HERE.

improving ML convictions and asset seizures and confiscations will need to be high on the list as with most countries.

For a PDF of the Dashboard see HERE: FCN Canada Dashboard FinalJC