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Project GUARDIAN – Renewing Public Service through Collaboration (December 2018)

Canada is facing a nationwide public health crisis as the number of overdose and death cases related to both prescription and illegal opioids, such as fentanyl, continues to increase at an alarming rate. This crisis does not discriminate and unfortunately most Canadians know someone who has been affected in one way or another by these substances. The crisis affects Canadians from all walks of life and has touched every part of the country from small towns to large cities.

In a national report by the Public Health Agency of Canada (released June 2018), there were 3,987 apparent opioid-related deaths in Canada in 2017 – 92 percent of which were accidental. This is an increase of 34 percent from 2,978 apparent opioid-related deaths in 2016. In response to this public health emergency, the Government of Canada is taking Federal Action on Opioids with a nationwide collaborative approach led by Health Canada.

What is FINTRAC?

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada’s financial intelligence unit. Its mandate is to facilitate the detection, prevention and deterrence of money laundering and the financing of terrorist activities, while ensuring the protection of personal information under its control.

For more information, please visit our website,, and follow us on Twitter, @FINTRAC_Canada.

In early 2017, recognizing the devastating effects of this epidemic on Canadian communities, FINTRAC swiftly began scouring its database for suspicious transactions involving fentanyl and sharing those with appropriate law enforcement partners. In February 2018, Project Guardian was launched as a new public-private sector initiative to combat the trafficking of illicit fentanyl. This initiative was built on the successes of Project Protect and Project Chameleon. Projects Protect, Chameleon and Guardian demonstrate the leadership of Canada’s financial institutions who not only want to comply with their obligations but are also willing to find innovative ways to help in the fight against money laundering and terrorist activity financing.

Drug traffickers in Canada and abroad seek to exploit Canada’s financial system to profit from the procurement and distribution of illicit fentanyl. They operate in a broad range of contexts to commit and conceal their crimes, and while their tactics and approaches may be different, there is one commonality—it’s all about the money. FINTRAC is focused on tracing the movement of funds related to the trafficking of illicit fentanyl.

Through a strategic analysis of its financial intelligence, and in collaboration with Canada’s financial institutions and the Royal Canadian Mounted Police, FINTRAC developed a comprehensive list of money laundering indicators showing how drug traffickers exploit the financial system to acquire fentanyl and to launder the proceeds of this illicit activity.

The indicators provided in FINTRAC’s Operational Alert, Laundering of the Proceeds of Fentanyl Trafficking, facilitates this reporting by assisting businesses in identifying transactions or attempted transactions where there are reasonable grounds to suspect money laundering related to the trafficking of fentanyl. Businesses that have a legal obligation to report financial transaction information to FINTRAC now use these indicators as triggers for suspicious transaction reports that may indicate the trafficking of fentanyl in support of Project Guardian.

As suspicious transaction reports have the potential to provide tremendous intelligence value to FINTRAC, they have become the focus of outreach activities and are often the foundation of its financial intelligence disclosures related to its public-private sector initiatives, including Project Guardian.

Under the leadership of the Canadian Imperial Bank of Commerce (CIBC), Project Guardian has mobilized the efforts of Canadian financial institutions and money services businesses, FINTRAC and Canada’s law enforcement agencies to combat the trafficking of illicit fentanyl. As a result of these efforts, FINTRAC has received a significant number of suspicious transaction reports related to the trafficking of illicit fentanyl.

Since FINTRAC has identified fentanyl as a priority, the Centre has generated 317 disclosures of actionable financial intelligence to date in support of the money laundering and fentanyl/drug trafficking investigations of Canada’s municipal, provincial and federal police agencies. Approximately eighty percent of these disclosures were proactive as they drew attention to possible cases of which FINTRAC’s partners may not have been aware. The Centre has also provided six disclosures to foreign financial intelligence units.

Disclosures related to fentanyl and Project Guardian between April 2017 and November 2018 Footnote 1

Yukon – 1 
Northwest Territories – 1 
British Columbia – 92 
Alberta – 94 
Saskatchewan – 15 
Manitoba – 3 
Ontario – 123 
Quebec – 10 
Newfoundland and Labrador – 2 
New Brunswick – 6 
Nova Scotia – 6

Other Successful Public-Private Partnerships

Project Protect (2016), initiated by the Bank of Montreal, is the first of its kind in the world and has directly led to the rescuing of dozens of women who have been trafficked in the sex trade. Project Chameleon (2017), led by the HSBC, has helped police to identify the perpetrators of romance fraud and to contact victims directly to stop the fraud and protect their money.

The fentanyl epidemic is a complex crisis that requires collaborative action from stakeholder groups and all levels of government in various sectors, including health, public safety, social, legal and economic. As a part of the Federal Action on Opioids, the Government of Canada is committed to protecting the health and safety of all Canadians, and FINTRAC is proud to contribute and support this important government-wide priority.

The Blueprint 2020 initiative aims to ensure excellence in public service by maximizing talent and working collaboratively to find innovative solutions to address challenges and provide better services to Canadians. By working together with businesses, police, law enforcement and national security agencies across Canada, FINTRAC used financial intelligence to identify potential subjects, to uncover broader financial connections, and to help advance national, project-level investigations.

Through the cooperation and collaboration with its partners, Project Guardian is providing effective results. With this innovative public-private sector initiative that targets illicit opioids, FINTRAC’s commitment to protecting the safety of Canadians and the security of Canada is clear. Together, and in close alignment with the Government of Canada’s broader efforts in relation to the opioid epidemic, we’re following the money to help identify drug traffickers and safeguard vulnerable communities.

For more information about Project Guardian or FINTRAC’s role in the Government of Canada’s response to the opioid crisis, please contact us at guidelines-lignesdirectrices@fintrac‐

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