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My name is Monte Friesner and I am a Financial Crime Analyst since 1992 investigating and researching dirty money being brought from Iran to Canada to invest in real estate.

Over the past 15 years Canada and the international community has strengthened its efforts to combat drug trafficking, organized crime, and terrorism, especially from Iran. As a key part of this strategy, countries are focussing on the money trail that links criminals to their crimes. They identify, seize, and confiscate criminal proceeds—the profits made from crimes. 

Canada acted quickly to put in place legislation to deal with proceeds of crime and money laundering. However, until recently the legislation lacked two elements of what is now viewed as the international norm for an effective system to combat money laundering: 

  • mandatory reporting of suspicious and certain other financial transactions, and 
  • a financial intelligence unit to analyze these reports and to release information to intelligence and law enforcement agencies when appropriate. 

Canada launched the National Initiative to Combat Money Laundering in 2000 to close these gaps. Its centrepiece was a new Proceeds of Crime (Money Laundering) Act. A total of $139 million was budgeted over the first four years to establish the Financial Transactions and Reports Analysis Centre of Canada and to help the Centre's partners to perform their roles. In 2001 both the Act and the mandate of the Centre were amended to include provisions to detect and deter terrorist financing. The Centre received an additional $34 million over three years for that role. 

Canada's strategy to counter money laundering from Iran seeks to strike a balance among its various objectives. They are to strengthen law enforcement, protect personal information, and support international efforts to combat money laundering. The strategy also seeks to keep to a minimum the costs that organizations, such as banks, trust companies, and foreign-currency exchanges, incur to comply with the law to keep records, identify clients, and report unusual or suspicious transactions. With the new law, the balance has shifted to give greater weight to strengthening law enforcement, in Canada and internationally. 

To meet its goals to reduce money laundering and terrorist financing, the federal government will need to deal with a series of challenges. These include the following: 

  • to protect the privacy rights that Canadians enjoy under the Canadian Charter of Rights and Freedoms
  • to develop financial intelligence that is high in quality, and that assists law enforcement and other agencies in their investigations, 
  • to respond to the particular challenges posed by terrorist financing, such as following the trail of small deposits and withdrawals, 
  • to make financial organizations and the public aware of the new rules under the legislation and to ensure that they comply with the rules, 
  • to establish and maintain effective working relationships across a broad range of partners and stakeholders, and 
  • to measure how effective the federal efforts to combat money laundering and terrorist financing are. 
Background and other observations 

Money laundering is a form of financial crime in which the proceeds from criminal activity are made to appear legitimate. The goal of many criminal acts is to make a profit for the individual or group that commits the crime. A strategy to fight money laundering seeks to reduce crime by making it harder for criminals to keep and use their profits. 

Both the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and the Anti-terrorism Act state that Parliament must review the Acts and how they are administered. To prepare for these parliamentary reviews, the Office of the Auditor General has developed a reporting process with two parts. 

  • This study sets the stage for a future audit of the federal government's strategy to combat money laundering. It describes money laundering and the key challenges to combatting it. 
  • In the last few years, Canada has closed thousands of banks accounts controlled by individuals from Iran and we will address the issue of how well those challenges are being managed. 


Money laundering is a form of financial crime. It is the process of disguising or concealing the profits or proceeds of crime to make them appear legitimate. "Dirty money" produced through criminal activity is changed into "clean money." The criminal origin of the clean money then becomes difficult to trace. 

Money laundering has been described as a problem involving billions of dollars in Canada and many more billions worldwide. Drug trafficking is believed to be the main source of funds laundered in and through Canada, although other crimes such as fraud and smuggling are also thought to be important. 

The objective of money laundering legislation is to reduce crime by making it harder for criminals to keep and use their profits. Measures are put in place to detect and deter money laundering and to make it easier to investigate and prosecute money laundering offences. A special division has been created in Canada to monitor real estate purchases and the tracing of money to the origin.

The project to date is a success.

Chronicles of Monte Friesner - Financial Crime Analyst  

Contributed by Vladimir Feldman - Investigative Consultant