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Canadian Money Laundering Concerns December 2012
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Receives financial transaction reports and voluntary information on money laundering and terrorist financing Ensure compliance of reporting entities with the legislation and regulations; Produce financial intelligence relevant to money laundering, terrorist activity financing and threats to the security of Canada investigations; Research and analyze data from a variety of information sources that shed light on trends and patterns in money laundering and terrorist financing; Maintain a registry of money services businesses in Canada; FINTRAC MANDATE 3
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RCMP 59% Municipal Police Services 18% Foreign Financial Intelligence Units 19% Provincial Police Services 21% Canadian Security Intelligence 15% Canada Border Services Agency 11% Canada Revenue Agency 18% Main disclosure recipients from FINTRAC 4
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Fraud 33% Drug 26% Unknown 14% Tax Evasion 5% Customs/Excise 5% Corruption 5% Human Smuggling 4% Theft 3% Illegal Gambling 1% Types of predicate offences related to cases in 2010 - 2011 5
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ML methods and techniques observed Structuring and smurfing: Cash purchases by one or many individuals of EFTs that fall under the reporting threshold; Currency exchanges under $10,000 from CAD to USD or vice versa; Cash purchase of money orders or bank drafts under $1,000 (which does not require identification) that are payable to third parties; Depositing a large number of $20 bills totaling under $10,000. Refining: Exchanging small-denomination bills for larger ones (e.g. $20 bills for $100 bills). 6
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ML methods and techniques observed Commingling: Financial transactions suspected to be a mix of legitimate business revenue with criminal proceeds; Businesses acting as fronts to make financial transactions appear more legitimate, indicated by multiple entities sharing a common address; Holding numerous business bank accounts and conducting various transfers between accounts. Funds are then moved to one account and bank drafts are purchased. Casinos - Cash purchase of casino chips, with minimal play, followed by the redemption of chips for either cash or cheque. 7
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ML methods and techniques observed Electronic funds transfers - Large funds transfers from a business account to individuals located in countries of concern. Foreign exchange transactions: Currency exchanges from CAD to USD or vice versa; Large cash deposits, converted to USD, then wired to a country related to drug trafficking; Currency exchanges followed by purchases of EFTs. 8
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Businesses used in suspected ML drug-related cases: Money Service Businesses Construction/development industry Shipping/freight companies Import/export companies Travel agencies Real estate Electronics Pharmaceutical 9
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Businesses used in suspected ML drug-related cases: Convenience/grocery stores Food and entertainment Auto industry Hydroponics/indoor gardening Trucking companies Gas stations 10
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Countries Canada Sent disclosures 1. United States of America 2. United Kingdom 3. Bahamas 4. Belgium 5. Hong Kong 6. France 7. Australia 8. Luxembourg 9. Singapore 10. Germany 11
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