Analyzing FINTRAC's annual report: Safe Canadians, Secure Economy

FINTRAC’s annual report was released on 1 December 2022, and there are some nice little tidbits in there about the state of financial intelligence in Canada, and the operation of the Centre. Today’s Insight Intelligence is a short summary of some of the bits I found most interesting (with my usual focus on terrorist financing / threat financing).

Let’s start with some shade. If anyone remembers the Cullen Commission report from earlier this year, that report criticized FINTRAC for the number of disclosures it shared compared to the number of reports that were available to the Centre.

A missed opportunity: Canada's Cullen Commission

I wrote in my critique of the commission’s report that this wasn’t a great criticism, because each disclosure could contain hundreds, perhaps thousands, of transaction reports. Seems like FINTRAC also shares my critique, as they wrote:

“For example, the 382 disclosure packages that we provided to municipal, provincial and federal law enforcement in British Columbia in 2021–22 were focused on 890 individuals and, in total, contained more than 30,000 transaction reports, with some reports including numerous transactions. The approximate value in the transactions relevant to money laundering investigations was $2.88 billion.”

(The “some reports including numerous transactions” is likely a reference to suspicious transaction reports that can include one or more specific transactions within the overall report.)

I read this as a direct rebuttal to the Cullen Commission’s critique. (For the record: there are plenty of things wrong with both FINTRAC and our AML/CFT regime. This just isn’t a particularly useful critique. Misses the mark, in my view.)