Presentations and Speeches

Notes for an address by FINTRAC Director
Jeanne M. Flemming, to the FINTRAC Toronto Workshop: Mapping the Continuum

September 29, 2009


Good morning and thank you all for being here.

This is the first time that FINTRAC has hosted a workshop of this type, and we are very pleased with the level of interest that has been shown.

We decided to host these workshops because of popular demand. There has been demand for more information and more insight into this whole anti-money laundering regime. We are here this morning in response to your requests for this type of information and your questions. Over the next two days, I hope you find answers to some of those questions.

Canada's efforts to detect and deter money laundering depend on a remarkable flow of information emanating from the many businesses engaged in financial transactions. Transaction information, in vast quantities, is received by FINTRAC to be aggregated, analyzed and assembled into a meaningful product-financial intelligence that assists investigations and prosecutions.

In putting on this workshop, our goal is to bring together the many parts of this regime continuum and to encourage an exchange of knowledge. I recognize that FINTRAC is only one part of this equation and that is why I am pleased that the bigger picture can be rounded out in this workshop with the participation of financial institutions, police and prosecutors.

This is a collective enterprise. And, I suppose, it is only fitting that we should collect ourselves from time to time to discuss how we can work better together.

Like so many things that are built one brick at a time, I hope that this workshop establishes a foundation for more collaboration.

FINTRAC does have a unique perspective on financial transaction activity in Canada. We owe much of that perspective to the banks and other businesses that have filed transaction reports. Through the many reports that we receive from every part of Canada, we have a unique vantage point on financial activity. We make use of that perspective to assist investigations and prosecutions.

The information contained in those transaction reports can be truly powerful when it is properly marshalled and analyzed. The right information, in the right hands, at the right time can make a difference.

It can identify connections between criminal activities in different parts of the country, it can identify hidden assets and it can be used to expand upon investigative leads within Canada and beyond its borders.


As the head of Canada's financial intelligence unit, I believe that financial intelligence can and does make a difference. The careful analysis of financial transactions can bring real insight to investigations. Financial transactions are a unique set of facts and thanks to the diligence and professionalism of the financial service sector they are reliable, detailed and well-maintained. The money trail that is created by these transactions reports can be the unavoidable vulnerability that brings a criminal to prosecution or identifies criminal proceeds for seizure and forfeiture.

The anti-money laundering system that has been built is more than a set of rules and compliance obligations; it is the result of the combined efforts of many people, of many disparate organizations and entities: businesses, FINTRAC, police and prosecutors.

Bringing together so many different organizations for this workshop presents an excellent opportunity to exchange information and to learn from each other. I hope that each of you learns something new and useful over the course of the next two days and that you feel encouraged bringing your own experience and expertise to the workshop discussions. We want and need your views and insights for these sessions to be a success.


Since taking on my role as FINTRAC's Director, I have recognized we should be offering more feedback to the many businesses that submit financial transaction information. Reporting entities, as essential participants in this initiative, you need to know how things are going and how your information is useful.

I realize that FINTRAC's work must appear mysterious to you and that is perhaps why the contributions of those filing transaction reports needs to be better understood and appreciated. Where possible, over the next two days, we will discuss the cases and instances where transaction reporting and transaction analysis have added some real value to investigative work.

In the spirit of mapping the regime continuum, we will have a case of money laundering presented from end to end, covering the many steps along the way from the reporting of the transactions, to their analysis and the eventual investigation and prosecution. We will also have a presentation from financial institutions about the trends that banks are observing. And we will have a presentation from FINTRAC that will reveal how we approach our analysis and how we identify and prioritize the cases that we will work on.

In May of this year, FINTRAC published a report for the Canadian banking sector and in collaboration with the Canadian banking sector that outlined trends and typologies in money laundering and terrorist activity financing. Some of the compliance officers who worked with us on that report are here today and I would like to acknowledge their contribution in shaping the subject matter of that report.

The banking sector report and this workshop are both the first of their kind. And I hope that both initiatives underscore a new openness on the part of FINTRAC and that they provide you some meaningful insight into this larger continuum-this larger initiative of connecting the money to the crime that we share.


I would now like to introduce our keynote speaker. I am very pleased that Assistant Commissioner Peter German of the RCMP agreed to participate and to speak to us this morning.

The RCMP, it should be said, is FINTRAC's biggest client. Much of the work we do is destined for RCMP investigations across the country. It is FINTRAC's goal to provide the RCMP something of real value to their investigations-a final product that boils down the millions of financial transactions into something that is not only clear and intelligible, but something that serves as intelligence in their investigative work.

We are very fortunate to have Assistant Commissioner German with us this morning. Few, if any people in this country, have had the sort of experience and depth of knowledge with this subject as Peter German.

Assistant Commissioner German is the District Commander for the lower mainland of British Columbia and very recently he served as the Director General for Financial Crime, responsible for commercial crime, market enforcement and money laundering programs.

He is a member of the bar associations of Ontario and British Columbia and has practiced law privately as a Crown Prosecutor and a criminal defence counsel.

Assistant Commissioner German has been at the forefront of Canada's efforts to establish an effective regime to combat money laundering. Some might say he has written the book-and that would be true. He has written the widely accepted legal text titled: Proceeds of Crime, which is devoted entirely to proceeds of crime and money laundering. He also serves as an adjunct professor of law at the University of British Columbia and at the University College of the Fraser Valley. He is a Senior Fellow at the Levin School of Law at the University of Florida.

These are only a few highlights of Assistant Commissioner German's career and the experience he brings to this subject. His perspective is both scholarly and practical, as he is one of the very few who can bring his experiences as an investigator, a lawyer, and an academic to bear on the subject of combating money laundering.

Only a few weeks ago, I had the opportunity to meet him at the Economic Crime Symposium at Cambridge University where he moderated a panel on the threats of organized crime to financial institutions. He is truly an international authority when it comes to money laundering and I look forward to hear what he has to say this morning.

Ladies and Gentleman, Peter German.