Speaking points for Sarah Paquet, Director and CEO of FINTRAC at the C.D. Howe Institute

Speech

Toronto, Ontario

April 23, 2026

Check against delivery

Introduction

I am delighted to have the opportunity to engage with one of Canada’s most respected research and policy think tanks.

Before I begin, I want to acknowledge that I am speaking to you from the traditional territory of many nations, and what is now home to many diverse First Nations, Inuit and Métis peoples.

As we confront unparalleled changes in the world order – what the Prime Minister has referred to as a global rupture – it is important that we recognize, leverage and defend our strengths as a country.

Canada is an open society, with strong democratic traditions and robust human rights protections.

We have the tenth largest economy in the world.

We have open and extensive trade with countries around the world.

We have a large, mature and stable financial system.

And we have world-leading Canadian businesses in tech, financial services, resource and other sectors.

That’s all very good news.

Threat posed by money laundering, terrorist financing and sanctions evasion

Now the bad news: foreign adversaries, transnational organized crime groups, international terrorist networks and others are working hard to exploit Canada’s strengths and good fortune.

There are more than 4,000 organized crime groups operating across the country. A number of these groups pose a high threat due to their entrenched networks and involvement in numerous types of criminal activities, all of which generate billions of dollars in profits every year.

Their pursuit of profit – whether it’s from extortion, fraud or drug trafficking – threatens our communities and our most vulnerable citizens.

Last fall, the RCMP in Ontario recognized FINTRAC’s contribution in dismantling one of the largest known drug trafficking operations on the dark web in Canadian history. Seven individuals were charged with dozens of offences and police seized 75 kilograms of illegal drugs and 10,000 pills. It is not hard to imagine the damage these drugs would have done in communities across Canada.

Organized crime also threatens Canadian businesses. According to a recent KPMG survey, 80 percent of businesses polled said they lost between one and five percent of their profits to AI-powered fraud attacks.

Ransomware attacks on businesses also continue to increase in scope, frequency and complexity. A study by cybersecurity firm Palo Alto Networks found that the average ransom paid by Canadian businesses was $1.13 million.

To enjoy the financial benefits of their crimes against Canadians and Canadian businesses and expand their illicit infrastructure and networks, organized crime groups must launder their proceeds through Canada’s financial system.

Large-scale and sophisticated money laundering operations in Canada almost always involve third parties, including professional enablers such as lawyers and accountants. These individuals have the credentials, training, infrastructure or other specialized knowledge to undertake complex money laundering schemes and facilitate illicit financial flows.

Organized crime groups also leverage advanced technology to facilitate their crimes and launder their profits. For example, the use of chatbots and AI-generated emails is escalating fraud and other scams, causing greater harm to more victims.

Criminals are using cryptocurrencies to obtain payments related to fraud and ransomware attacks, and to distance the proceeds from their criminal source. Crypto users have a high degree of anonymity and global reach. This allows for rapid cross-border transfers and access to high-risk jurisdictions.

Beyond threatening Canadians and Canadian businesses, money laundering undermines the integrity of our financial system and harms Canada’s legitimate economy, which our businesses rely upon: it distorts market prices, creates unfair competition and damages the reputation of our financial sector.

More broadly, money laundering fosters corruption and leads to the erosion of public institutions and the rule of law, lower government revenues and a loss of credibility and influence internationally.

Terrorists and those supporting terrorism also look to exploit Canada’s financial system to facilitate their devastating activities. Whether it’s individuals engaged in ideologically motivated violent extremism here in Canada, extremist travellers or international terrorist groups, we have seen how they move their money to facilitate their terrorist activities.

We have also seen a growing nexus between terrorism and transnational organized crime, creating a bond of mutual interest. Terrorists are leveraging organized crime for logistical support and to finance their activities through extortion, kidnapping for ransom and other illegal operations. Last year, Canada listed several transnational organized crime groups as terrorist entities for their involvement in terrorism related activity.

Protecting Canadians and Canada’s financial system

So what are we doing to protect Canadians and Canada’s financial system?

As Canada’s anti-money laundering and anti-terrorist financing supervisor and financial intelligence unit, FINTRAC is at the heart of a broader national regime that Canada has in place to combat these threats.

Our role is to ensure that financial institutions, casinos, money services businesses, real estate and certain other business sectors fulfill a number of regulatory obligations. This includes identifying clients, keeping records and reporting certain financial transactions to FINTRAC.

These obligations provide important measures to deter criminals and terrorists from operating within the legitimate economy. The requirement for clients to identify themselves is a measure of deterrence as it eliminates the anonymity of the customer. And, because these activities are documented, they can be traced later, if necessary, for evidentiary purposes.

The reporting obligations also ensure that we receive the information that we need to generate actionable financial intelligence in support of law enforcement and national security investigations.

Money is both an enabler and a vulnerability for organized crime and other bad actors. When criminals and terrorists move their money within the financial system, it leaves a trail – even on so-called anonymous platforms. This trail can connect individuals to crimes and to broader networks, and it can link different networks to each other.

By following the money, FINTRAC helps to target, disrupt and dismantle organized crime and terrorist networks.

Our financial intelligence is used by police to launch investigations, confirm existing information, identify links between individuals and businesses, and help refine the scope of their cases or shift their sights to different targets. It is often critical to putting together affidavits to obtain search warrants and production orders.

Last year, our financial intelligence identified over 8,600 subjects of interest, included more than 1.3 million financial transactions, and supported hundreds of law enforcement and national security investigations at the municipal, provincial and federal levels across Canada, and internationally.

In December, the RCMP’s Integrated National Security Enforcement Team recognized FINTRAC’s contribution to an investigation here in Toronto into terrorism-related offences. An individual was charged with providing property to be used to carry out terrorist activity and providing property to fund or benefit a terrorist group, namely ISIS.

Our financial intelligence is also used by authorities to seize assets, support applications for the listing of terrorist entities, and advance the government’s knowledge of the financial dimensions of threats, including organized crime, terrorism and sanctions evasion.

Delivering on key priorities – Leveraging the power of financial intelligence

Given the emerging threat landscape, what is our current focus?

First and foremost, we are delivering on our core financial intelligence mandate and supporting pressing national priorities.

I recently joined Minister Champagne in Toronto and Montréal to announce that we are surging support to combat extortion that is taking place across the country, as part of the federal government’s broader response to tackling this threat to Canadians and Canadian businesses.

In communities across the country, criminal networks are targeting individuals and businesses using threats, intimidation and violence to coerce victims into taking unwanted actions, including making payments to stay safe. We are working to put an end to this.

We have sent Financial Intelligence Officers out across the country, including throughout the GTA, to engage directly with local police and provide on-the-ground financial intelligence expertise. This is ensuring that law enforcement is able to fully leverage our intelligence in their extortion-related investigations and disruption activities.

Since the beginning of the year, we have generated well over 100 financial intelligence disclosures related to extortion for law enforcement across Canada.

We have also worked closely with Canada’s largest banks and law enforcement to identify the financial transaction trends and typologies associated with extortion.

Today, we are publishing a special bulletin capturing the financial activities related to extortion and violence targeting Canada’s South Asian diaspora communities here in the GTA and across Canada. This bulletin will help businesses detect this criminal activity and report suspicious transactions to FINTRAC, which is critical to our ability to generate actionable financial intelligence for police.

Beyond extortion, we have surged our support to the federal government’s fight against illegal fentanyl.

Earlier last year, we established a rapid intelligence production team to prioritize the disclosure of actionable financial intelligence related to illicit opioids and transnational criminal organizations. Since January 2025, we have generated more than 300 financial intelligence disclosures in support of law enforcement investigations. We are also providing expertise and support to the RCMP’s Joint Intelligence Operational Cell and Canada’s Fentanyl Czar.

We are contributing to Canada’s National Action Plan on Combatting Auto theft. Our financial intelligence was recognized by the Peel Regional Police in relation to Project Odyssey, an investigation into an organized crime group responsible for the theft and transportation of stolen vehicles through hubs across the GTA to the Port of Montréal. The investigation resulted in the arrest of 16 individuals and the recovery of 369 stolen vehicles with a value of more than $33 million.

We are helping to combat human trafficking, a heinous crime targeting Canadian women and girls here in Ontario, particularly along the 401 corridor, and across the country. Last year, our intelligence identified more than 530 subjects of interest and supported 26 project level investigations.

The Halton Regional Police Service recognized our assistance following a lengthy human trafficking investigation. Police alleged that two individuals were using physical violence and psychological harm to control and traffic multiple women in the GTA for their own financial benefit. The individuals were charged with, among other crimes, assault, sexual assault and human trafficking.

In the case of human trafficking for sexual exploitation, the traffickers often target Canada’s most vulnerable citizens, with the majority of victims being women under the age of 25, including minors as young as 12.

We have also been active in helping to combat the increasing threat, and terrible damage done by, fraud targeting Canadians and Canadian businesses, particularly cyber-enabled fraud. More than 25 percent of our financial intelligence disclosures last year identified fraud as the primary criminal offence, including cryptocurrency fraud.

The RCMP's Cybercrime Investigative Team in Toronto recognized our contribution to an investigation last year that resulted in the arrest of two prolific cyber fraudsters who had scammed at least 570 Canadians out of millions of dollars.

With its ever-growing impact on Canadians and Canadian businesses, fraud will remain a priority focus for FINTRAC. This includes supporting Canada’s first-ever whole-of-government National Anti-Fraud Strategy, when it is completed, and the work of Canada’s future Financial Crimes Agency.

Delivering on key priorities – Strengthening oversight and partnerships

It takes a committed network to defeat organized crime and terrorist networks here in Canada and around the world. This is why we are strengthening our oversight of, and partnership with, regulated businesses.

We are committed to working with businesses to ensure they are aware of emerging threats and focus their compliance efforts on national priorities – combating extortion, disrupting fentanyl trafficking, fighting fraud and dismantling organized crime. Our strategic intelligence provides practical support to businesses in identifying and acting on suspicious and high-risk transactions.

As a priority, we are engaged in more targeted and technologically advanced oversight of businesses dealing in virtual currency to address the risks in this rapidly evolving sector. Since March, we have revoked the registrations of more than 150 money services businesses, a number of which were offering virtual currency services here in Toronto.

Last October, we issued the largest penalty in FINTRAC’s history – over $176 million – to a business providing virtual currency services. Among other violations, the business failed to submit suspicious transaction reports where there were reasonable grounds to suspect that they were related to trafficking in child sexual abuse material, fraud, ransomware payments and sanctions evasion.

With our enhanced risk-based approach to supervision, we are also increasing our oversight of Canada’s financial institutions given their significant transaction volumes, their scope of operations domestically and internationally and the large number of vulnerable products and services they offer. Canada’s financial services sector is mature, resilient and a core foundation of our economy. It is also a primary target of bad actors.

We are scaling up our oversight of newly regulated entities, including mortgage brokers and lenders, and new legislative requirements related to beneficial ownership and sanctions evasion. Given the current geopolitical landscape, we are working closely with businesses, in particular, to help deter and detect illicit funds and goods flowing to Iran and Russia.

We are also focused on the money laundering risks in the online gaming universe and will be taking targeted measures to tackle the growth of illegal gaming and gambling platforms across Canada.

As we take aim at the greatest threats to Canada’s financial system, we are in the process of implementing significant legislative and regulatory changes in relation to the Strengthening Canada's Immigration System and Borders Act, which came into force on March 26.

FINTRAC has joined the Financial Institutions Supervisory Committee (the FISC), which includes Finance Canada, the Bank of Canada, OSFI and others. This will enable better coordination across agencies in fighting financial crimes.

We are building a streamlined universal enrolment program for all 38,000 regulated entities. This will bring thousands of businesses out of the shadows, increasing our visibility into their operations and enhancing our ability to enforce legislative and regulatory requirements.

We are also strengthening the enforcement framework for our administrative monetary penalties with the new Act increasing the size of our penalties by 40 times the current amounts. With this change, Parliament has made it very clear to businesses that non-compliance cannot be treated as the cost of doing business.

Our priority is to support businesses in complying with their obligations. However, Canadians can expect significant penalties – including in the tens or hundreds of millions of dollars – when businesses are not meeting their moral and social responsibility to combat financial crimes.

With the Strengthening Canada's Immigration System and Borders Act, we also have the authority to issue Compliance Orders when entities fail to address their violations. These orders will be made public and failure to comply with them can result in a penalty of up to $30 million or three percent of the entity’s global revenues.

Delivering on key priorities – Deploying modern technologies

As we strengthen our supervisory efforts, we are also accelerating our digital transformation by deploying cutting-edge technological solutions and modernizing our systems to enable our heightened oversight of regulated entities.

For example, we are looking to develop a next-generation portal that will allow for streamlined reporting, real-time guidance and timely regulatory updates. By improving data quality and automating processes, we will be able to close compliance gaps, enable proactive risk management, and better support Canadian businesses in meeting their obligations.

The digital transformation of our supervisory efforts is closely aligned with our broader real-time modernization vision. With this vision, we are advancing FINTRAC-wide digital automation, leveraging artificial intelligence and machine learning, and pioneering data analytics to strengthen our financial intelligence and supervisory programs.

In combatting extortion, for example, real-time financial intelligence capabilities will allow us to proactively – and more quickly – identify and assist police in disrupting networks that threaten Canadians. This means police can target perpetrators faster and prevent the abuse of new victims. This is the essence of our work – helping to protect Canadians, Canada’s businesses and Canada’s broader financial system.

A call to action

We cannot do this alone. Everyone here today has a role to play.

For those of you working as leaders in a regulated business, your compliance efforts are essential to the success of Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime. You are the front line of Canada’s financial system. You help to keep the bad actors out and your reporting is the lifeblood of our financial intelligence efforts.

For those of you on the boards of regulated businesses, your work is key in ensuring your organization truly understands its risks, that your compliance efforts are appropriately funded and that there are concrete measures in place to ensure they are effectively addressing those risks. Your efforts will help ensure that your organization does not face significant financial and reputational harm for putting Canadians and Canadian businesses at risk.

For the experts, researchers and academics here today, your efforts are critical in helping us to identify rapidly emerging and evolving threats and risks, in an unprecedented period of change, and in closing gaps that threaten Canadians and Canada’s financial system.

For opinion leaders and stakeholders, we need your assistance in increasing awareness of the broader threat posed by money laundering, terrorist financing and sanctions evasion. These are not victimless crimes – they threaten all of us. We need to continually thicken our defences – this takes commitment, resources and, ultimately, the support of Canadians.

As a call to action, let’s commit to taking a Team Canada approach to countering these threats and protecting our country.