Highlights of Gender-based Analysis (GBA) Plus at FINTRAC

FINTRAC is dedicated to ensuring that its activities - across policies, programs and initiatives - align with the Government of Canada’s commitments to GBA Plus. By taking an intersectional approach to its policies, programs and initiatives, FINTRAC is able to consider how multiple interrelated factors influence economic, social and health opportunities and outcomes, as well as barriers to accessing systems, programs or services.

Section 1: Institutional GBA Plus governance and capacity

The Centre engages a GBA Plus Champion, who is responsible for promoting GBA Plus, including raising awareness of events, encouraging GBA Plus training and disseminating relevant information to support the application of intersectional analysis throughout the Centre.

The Champion integrates into FINTRAC’s broader governance structure by reporting commitments and progress to the Centre’s Management Advisory Committee and Executive Committee.

In its role as Canada's financial intelligence unit and anti-money laundering and anti-terrorist financing regulator, FINTRAC has limited ability to directly influence the economic and social outcomes of GBA Plus in Canadian society. Integrating the objectives of GBA Plus into its program outcomes, as well as policy and legislation/regulation development is difficult given that the primary focus of its business is the receipt and analysis of financial transaction reports submitted by reporting entities. However, FINTRAC has developed capacity and expertise in GBA Plus and intersectional analysis, primarily through its Strategic Policy and Review unit, where, operationally, policy analysts are required to complete GBA Plus or related intersectional training on an annual basis. Further, the Centre recommends that employees in positions with analyst, policy and program type functions complete the Introduction to Gender-based Analysis Plus (GBA Plus) course as part of their regular training and learning program.

In the first half of 2023-24, the Champion was supported by a GBA Plus focal point housed within the Strategic Policy and Review unit of the Centre. The focal point contributed to intersectional analyses and supported regular monitoring and reporting on the GBA Plus program. With the scheduled renewal of the Centre’s Champions, in the second half of the fiscal year, the newly-appointed Champion initiated the development of a responsibility centre comprised of employees from a multitude of sectors at FINTRAC.

Section 2: Gender and diversity impacts, by program

Core responsibility: Compliance with Anti-Money Laundering and Anti-Terrorism Financing Legislation and Regulations

Program name: Compliance

Program goals: FINTRAC is responsible for ensuring compliance with Part 1 and Part 1.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its associated Regulations. This legal framework establishes obligations for reporting entities to develop and implement a compliance program in order to identify clients, monitor business relationships, keep records and report certain types of financial transactions. FINTRAC undertakes enabling and enforcement actions to ensure that the reporting entities operating within Canada's financial system fulfill their PCMLTFA obligations.

FINTRAC’s Compliance program recognizes that obligations for reporting entities to identify their clients can have disproportionate impacts on different sub-sets of the population. For example, survivors of human trafficking for sexual exploitation may not have proper identification documentation or information to open a retail deposit account. Survivors of human trafficking often find themselves in a situation where traffickers have confiscated their personal effects, including identification documents, bank cards, or have incurred debt in their name, creating a barrier to accessing the legitimate financial system. It can dehumanize and rob individuals of their autonomy and further victimize survivors in instances where they are trying to become full participants in the Canadian economy. In recognizing the impacts on survivors, FINTRAC, working under the umbrella of the global Finance Against Slavery and Trafficking (FAST) Survivor Inclusion Initiative, has maintained guidance in relation to client identification in respect of vulnerable clients.

Target population: Women, individuals of particular socio-economic status

Key program impacts and specific demographic group outcomes

FINTRAC’s guidance is designed to aid businesses in providing financial services to vulnerable or marginalized clients, while maintaining the businesses’ ability to meet their anti-money laundering and anti-terrorist activity financing requirements. In this regard, this initiative is expected to benefit multiple groups, rather than one distinct group with interesting characteristics. As the impetus for the initiative centered on victims of human trafficking for sexual exploitation, it is expected that it will disproportionately benefit survivors of that criminal activity. Based on FINTRAC’s analysis of transaction reporting, victims are predominantly female and a majority are under 25 years old. Some were minors.

Core responsibility: Production and dissemination of financial intelligence

Program name: Financial intelligence

Program goals: FINTRAC is mandated by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) to produce actionable financial intelligence that assists Canada's police, law enforcement, national security and other international and domestic partner agencies in combatting money laundering, terrorism financing and threats to the security of Canada, while protecting the personal information entrusted to FINTRAC. The Centre also produces strategic financial intelligence for federal policy and decision-makers, the security and intelligence community, reporting entities across the country, international partners and other stakeholders.

FINTRAC’s Financial Intelligence Program recognizes that specific predicate offences to money laundering can have outsized impacts on victims of specific demographic groups. Working with the private sector, law enforcement and non-governmental organizations, FINTRAC is a key player in developing and operationalizing public-private partnerships (PPPs) that prioritize reporting and the generation of financial intelligence targeting specific predicate offences such as human and drug trafficking, as well as online child sexual exploitation.

Project CHAMELEON

Project CHAMELEON is an ongoing PPP initiative to detect, deter and prevent romance fraud. Romance fraud involves perpetrators expressing false romantic intentions toward victims to gain and then take advantage of their trust and affection in order to access their cash, bank accounts and credit cards. The Canadian Anti-Fraud Centre has found that romance fraud victims account for some of the highest dollar losses per year from mass marketing frauds in Canada. However, romance fraud is one of the lowest reported types of mass marketing fraud, because victims can be ashamed to come forward, or may be unaware or unwilling to accept that they are a victim. As FINTRAC’s operational alert for this initiative notes, these cases of fraud can often result in financial loss to victims in vulnerable stages of life (i.e., a senior or widowed, separated or divorced). This is a crime where the victims are largely elderly individuals.

Target population: Single person households, individuals over the age of 60.

Key program impacts and specific demographic group outcomes

Project CHAMELEON is designated to improve the detection and deterrence of romance fraud through the development and use of financial intelligence related to this specific crime. In this regard, it disproportionally benefits elderly individuals, often who are divorced or widowed. By prioritizing this financial intelligence through the PPP model, it reduces the potential size and scope of victimization amongst the elderly population.

Underground banking

FINTRAC published an operational alert regarding the laundering the proceeds of crime through underground banking schemes. Underground banking refers to banking activities that run parallel to and operate outside of the formal banking system, commonly in the form of an informal value transfer. Informal value transfer systems involve dealers who facilitate the transfer of value to a third party in another jurisdiction without having to physically move the items. Informal value transfers can be used by illegitimate actors to conceal proceeds of crime, however, they are also commonly used among religious and racialized groups, expatriates and recent immigrants as a send money back to their families and friends in their home countries. Legitimate companies, traders, and government agencies needing to conduct business in countries with no or inadequate formal financial systems can also make use of these systems.

This operational alert is designed to raise awareness amongst reporting entities of possible indicators of money laundering. Reporting entities use this information to scrutinize transactions and report suspicions to FINTRAC. As distinct population groups disproportionately make use of informal value systems, the operational alert may inadvertently raise additional scrutiny for suspicions of money laundering or terrorist financing, and may result in more reporting to FINTRAC.  

Target population: Newcomers or immigrants, visible minority communities

Key program impacts and specific demographic group outcomes

The operational alert on underground banking mitigates some of the disproportionate impacts by identifying key geographic areas where the informal value transfer system has repeatedly been used to conceal illicit proceeds. While this reduces the potential inadvertent impacts on the target population, the remaining indicators may compel reporting entities to apply additional scrutiny on legitimate transactions using informal value transfer systems.

Definitions

Scales

Gender scale

• First group: predominantly men (80% or more men)
• Second group: 60% to 79% men
• Third group: broadly gender-balanced
• Fourth group: 60% to 79% women
• Fifth group: predominantly women (80% or more women)

Income‑level scale

• First group: strongly benefits low‑income individuals (strongly progressive)
• Second group: somewhat benefits low‑income individuals (somewhat progressive)
• Third group: no significant distributional impacts
• Fourth group: somewhat benefits high‑income individuals (somewhat regressive)
• Fifth group: strongly benefits high‑income individuals (strongly regressive)

Age‑group scale

• First group: primarily benefits youth, children or future generations
• Second group: no significant intergenerational impacts or impacts on generations between youths and seniors
• Third group: primarily benefits seniors or the baby boom generation