Vancouver Realtor suspended over

association with Chinese

website

Alban Wang paid $208,881 out of his commissions by

17 deals referred to him from Chinese real estate website

Posted: Aug 25, 2016

A Richmond real estate agent has been suspended for a year after admitting to paying more than $200,000 in relation to sales referred to him by a Chinese website.

A Richmond real estate agent has been suspended for a year for paying more than $200,000 for referrals on 17 house sales which came to him from a Chinese website dedicated to pushing B.C. real estate.

According to a consent order posted by the Real Estate Council of B.C., Xiao Ming (Alban) Wang did not tell purchasers who used the website he was remitting 90 per cent of his commissions in exchange for their business.

Wang's name was not on the site. He has been disciplined for paying referral fees to an unlicensed brokerage without disclosing the fact to clients.

'He agreed ... because it was easy'

The identity of the website and its owners are blanked out in the disciplinary documents, but the name Vanfun.com appears unredacted at one point.

Vanfun.com came under scrutiny earlier this year for appearing to post new properties for sale in Shanghai before they became available to customers in the Lower Mainland.

According to the consent order, the website Wang dealt with is headquartered in China, but the woman who launched it has a home in Richmond and has previously been a director of a B.C.-incorporated company.

Wang told the council he was approached by a former client in September 2012, who said a friend called FN was in search of a Realtor. Wang met with the woman a few days later.

She told him she was going to launch a website displaying comprehensive housing data and information about schools, prices, numbers of days on the market and historical records of transactions.

The website Vanfun.com came under scrutiny for appearing to post new properties for sale in Shanghai before they became available to customers in the Lower Mainland. (Vanfun.com)

"Wang stated FN told him she would introduce him to customers, almost all of whom had determined which properties they wanted to purchase," the consent order reads.

In exchange for 90 per cent of his commission, Wang was required to arrange showings, draft contracts for purchase and sale and present offers.

"Wang stated that he agreed to the arrangement because it was easy," the consent order says.

"Wang also stated that his name never appeared on any advertising for Vanfun.com, and he was never issued with any business cards."

Between November 2012 and July 2013, Wang said he completed 17 property transactions on homes in Vancouver, Richmond, Surrey, Coquitlam, Port Moody, West Vancouver and White Rock.

He told the council he paid a total of $208,881 out of his commissions.

'Shadow-flipping' lawsuit

Wang was previously disciplined by the real estate council in 2012 for collecting deposits and waiting as long as 67 days to hand them over to a brokerage. The council identified 12 transaction and a total of $785,000 worth of deposits in that case. Wang was suspended for 14 days and ordered to pay $1,000.

The latest disciplinary measures also include a fine of $10,000, the maximum the council can levy.

In a separate matter, Wang is being sued by a pair of brothers who claim he was operating a "real estate scam" in Richmond aimed at convincing owners to sell their houses for the purposes of "shadow-flipping".

The B.C. Supreme Court claim alleges the plaintiffs sold their home after receiving a pamphlet from someone named 'Sunny' who was interested in purchasing their property.

The brothers claimed they met with 'Sunny' and Wang, with whom they signed a limited dual agency agreement. The court claim says the sales contract contained an addendum allowing the buyer the right to assign the contract.

After selling the house, the brothers claim they learned the "property had been relisted for sale, presumably under the assignment clause as a shadow flip."

In their response, Wang and the real estate firm named in the suit deny "being a party to any conspiracy or scam."

They claim the brothers had done their own research and knew the market value of the property. The response says Wang and the firm had no knowledge 'Sunny' intended to assign the contract to another buyer.

Wang claims he first learned about the move to assign the contract several weeks after the contract was executed.

The response also notes the brothers agreed to the addendum explicitly providing the buyer the right to assign the contract.

None of the allegations have been proven in court.

Wang declined to comment on the real estate council's current order.

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Dirty money: it’s a Canadian thing

Dirty money: it’s a Canadian thing

Canada’s housing markets are rife with shadowy buyers and greasy cash. B.C. was just the beginning.

Jun 12, 2019

On paper, Peter Zhang and his wife, Judy Wang, were models for the type of newcomers Canada wanted to attract with its immigrant investor program. Before it was scrapped in 2014, the program’s aim was simple: lure the world’s wealthy to Canada’s shores with the promise of a passport. In return they would bring their business savvy, invest in the economy and create jobs.

Zhang and Wang were undeniably rich. They arrived from China at the end of 2010 with at least $6 million, settling in the suburbs north of Toronto. But almost immediately after, a twisting tale was set in motion that would eventually see Wang accuse a realtor, a lawyer and others of fraud and negligence, and prompt an Ontario judge to raise questions about both the source of Zhang and Wang’s wealth and a string of real estate and mortgage transactions tied to the case.

At the start of 2011, the couple bought their ﬁrst home, a six-bed, ﬁve-bath pile in Richmond Hill, Ont., for $1.25 million—and paid for it entirely in cash. By February, however, Zhang and Wang had separated, claiming in court that they divorced in 2013, though Ontario Superior Court Justice Paul Perell, in a November 2017 decision on a procedural matter in the lawsuit, described the divorce decree as “suspicious.” (In an email through her lawyer, Wang now says they divorced in June 2018.) Regardless, the pair continued to buy and develop three more Richmond Hill and nearby Thornhill properties together, largely in cash, through their joint company Yi Hao Investments. Wang bought a fourth property on her own in Vaughan with a 100 per cent loan-to-value mortgage from RBC in 2017. All told, she and Zhang bought ﬁve properties, worth $9.3 million at the time of purchase.

Aside from real estate, a considerable chunk of Zhang and Wang’s wealth was going to cover Zhang’s gambling activities. Over the next several years, Wang testiﬁed, she transferred up to $6 million to him from the sale of properties. (Justice Perell noted in his decision that neither Wang nor Zhang had any employment or business interests in Canada beyond real estate investing.) Meanwhile, the couple entered into a series of byzantine mortgage transactions with real estate agent Yan-Ling Ding and lawyer Rahul Kesarwani to generate cash for Zhang’s gambling. For instance, at one point, according to Justice Perell’s ﬁndings, Zhang’s ownership of Yi Hao was transferred to Ding to conceal Zhang’s identity so he could obtain a $900,000 mortgage from CIBC, while Kesarwani arranged a high-interest $150,000 private mortgage from his own ﬁrm for Zhang. (Ding and Kesarwani were offered the opportunity to comment through their lawyers but didn’t respond, while attempts to reach Zhang were unsuccessful. Through her lawyer, Wang said she was unable to provide contact information for Zhang “at this time.”)

READ MORE: Real estate photos are distorting reality, frustrating would-be home buyers

In 2017, Wang sued several people, including Ding for mortgage fraud and Kesarwani for negligence and breach of ﬁduciary duty. None of the allegations have been proven in court. Justice Perell did, however, offer his ﬁndings on the various transactions and testimony in a decision about procedural matters later that year. He didn’t hold back. Ding engaged in a “very suspicious” mortgage transaction, the judge wrote, while Kesarwani’s behaviour was “problematic.” Perell saved his harshest language for Wang and, in particular, Zhang, writing that he found their testimony to be “self-serving, implausible, inconsistent, illogical, incredible, unreliable, evasive and inconsistent with the documentation.”

But Justice Perell also raised questions that are increasingly being asked across the country in other cases: Where did the money come from, and how was it moved to Canada? Wang, on the advice of her lawyer, declined to answer those questions during her testimony. But in his decision, Perell highlighted the sworn testimony of several of the defendants. “[The defendants] believe that Mr. Zhang was a criminal who managed to get his wealth out of China to become a money launderer in Canada,” he wrote. “I make no ﬁnding other than saying that it is unknown how Ms. Wang and Mr. Zhang acquired their considerable wealth or how they got it out of China for investments in Canada.”

In her email to Maclean’s, Wang now says she was a part owner of a company involved in reselling steel products, that their money was transferred to a “Schedule I Canadian bank,” though she didn’t say which one. She also said she had “no knowledge of money laundering by Peter Zhang.”

The irony, of course, is that were it not for Wang’s decision to launch the lawsuit, it’s unlikely any of the details contained in this bizarre case—which was referenced in a recent report by Transparency International about the opacity of Toronto’s real estate market—would have ever come to light.

Image result for Peter Zhang Judy Wang, money laundering Richmond Hill, Ont.

Image result for Peter Zhang Judy Wang, money laundering Liberals Clark

Canadians have learned a lot in the past few months about some of the forces that contributed to the astonishing run-up in real estate prices over the last decade and a half. Many of these revelations have emerged from British Columbia in recent weeks with the release of two landmark reports on money laundering that sought to estimate the scale of the province’s dirty money problem, and detail how it tightened its grip on the housing market and other industries.

The gush of ill-gotten gains into the economy is deeply troubling. An expert panel set up to examine money laundering’s influence on B.C.’s real estate sector “conservatively” estimated in its report that $46.7 billion was laundered in Canada last year. Of that, the panel estimated that transactions in B.C. accounted for $7.4 billion. All that shady money pushed up home prices, too. The panel “cautiously” estimated that property prices are 3.7 to 7.5 per cent higher than they would have been without the effect of money laundering. That’s for the province as a whole. The ﬁgure would be higher in markets like Greater Vancouver, where money laundering activity is concentrated.

RELATED: What $2-million will buy in five Canadian real estate markets

But the panel also contained unpleasant surprises for other parts of Canada. Using what’s known as the Gravity Model for its estimates—which factors in international trade flows, per capita GDP and crime statistics—it found that Alberta and Ontario have even higher levels of money laundering activity. Maureen Maloney, a Simon Fraser University professor and chair of the panel, acknowledges the limitations of any model to put a dollar ﬁgure on a crime that by its nature lurks in the shadows. But this, she says, should be a wake-up call for other provinces. “People like to say this is only a B.C. problem,” says Maloney, “but it’s clear that this is a problem facing all of Canada.”

The B.C. NDP government is not sitting back. The panel made 120 recommendations for ways it and the federal government can crack down on money laundering, and B.C. Attorney General David Eby has already taken action on several of them, including a pledge to establish a public registry of the beneﬁcial owners of all residential property in the province. (Beneﬁcial owners are those individuals who ultimately own the property, even if the title may be in another person’s or corporation’s name.) B.C. Premier John Horgan has launched a public inquiry into money laundering in the province.

The response from provinces like Alberta and Ontario has been less inspired. Alberta Justice Minister Doug Schweitzer largely dismissed the panel’s ﬁndings about the scale of money laundering in the province. “We use intelligence from front-line law enforcement agencies, not data we can’t verify,” he told reporters dryly. “We will continue to work with our law enforcement partners to protect law-abiding Albertans.”

The Ontario government insists it already has the issue well in hand. Finance Minister Vic Fedeli’s ofﬁce said he would not be available for an interview, but released a statement. “We take this topic seriously, and criminal activity will not be tolerated in Ontario,” it read. “Ontario’s police services are well-equipped to investigate and take appropriate steps when illegal activity is identiﬁed.”

The undercurrent of denial and complacency in these responses worries experts, who warn the inevitable effect will be a shift in illicit activity away from B.C. to provinces where launderers are less likely to get caught. “As a money launderer, you’re going to go to those jurisdictions where you’ll have less chance of being investigated and less chance of being under scrutiny,” says Maloney.

Kevin Comeau, a retired lawyer and advocate for greater transparency in property ownership, is even more blunt: “While money launderers in B.C. could leave Canada altogether, they’re more likely to head to Ontario, because it has among the weakest anti-money laundering laws of all the Western liberal democracies.”

Luxury homes in Richmond Hill, Ont.: The real estate industry has a ‘deplorable’ track record when it comes to flagging dubious transactions

The signs of suspicious transactions are everywhere in B.C. But Belmont Avenue—west of downtown Vancouver in the upper-class neighbourhood of Point Grey—is as good a place as any to start. The street boasts ﬁve of Vancouver’s 10 most expensive properties, and on a sunny day it’s not hard to see why: the houses are located above the Spanish Banks beaches and have unfettered views of the North Shore Mountains.

Save for the clatter of hammers at nearby construction sites, the avenue is eerily quiet and empty for a cloudless afternoon. Many of the homes have curtains drawn across every window. It could be that the inhabitants want to protect their privacy; it’s also possible the homes are vacant. Many on Belmont were named in a 2016 Transparency International report as properties owned through shell companies, or suspect nominees, flagging them as possible money laundering sites. Tian Yu Zhou, listed on land records as a “student,” bought one of the properties, a sprawling cedar-panelled house, for $31.1 million in 2016. Zhou has a 99 per cent ownership stake; his mother, Cuie Feng, listed as a “businesswoman,” owns the other one per cent.

It’s no secret that much of the money flowing into B.C.’s real estate market is coming from China. In one now-famous study, Andy Yan, director of the City Program at Simon Fraser University, examined 174 property transactions over a six-month period in Vancouver’s affluent west side and found that two-thirds of all sales were to buyers with non-anglicized Chinese names, an indicator they were recent immigrants from mainland China.

READ MORE: Real Estate: What $250,000 will buy in four Canadian cities

“Everyone is interested now in how much of that money coming from China is legitimate,” says Christine Duhaime, a ﬁnancial crime lawyer who has assisted Chinese companies in recovering money stolen from the country that found its way into Vancouver’s real estate market. China has long maintained capital controls that allow its citizens to exchange and withdraw only US$50,000 a year. Other than that, citizens need explicit approval to move their money out of the country.

To show how creative some are getting to circumvent those limits, which have grown more restrictive in recent years, Duhaime points to one case she’s aware of, in which a businessman in China loaded 180 employees onto buses, each carrying a duffle bag stuffed with US$50,000 in cash, and shuttled them to the bank. The employees deposited the money into their accounts and then wired the funds to their boss in Vancouver. The flurry of wire transfers failed to trigger any red flags at the Canadian bank, she says: “For too many years, the banking industry in Canada has taken a position that we don’t ask questions about the providence of money from China.”

Even when money laundering cases do emerge, police in B.C. are woefully short of resources to pursue them. As it stands, there are no federally funded RCMP ofﬁcers dedicated to investigating money laundering crimes in the province, and prosecutors have a poor track record of bringing such cases to a close. Since 2002, only 10 people have been convicted of money laundering in B.C., according to Henry Tso, a retired RCMP superintendent who now works in fraud mitigation at accounting ﬁrm MNP. Often prosecutors opt to drop money laundering charges in cases to focus on charges like drug trafﬁcking that are more likely to result in convictions.

“These cases are more complex to investigate and harder to prosecute than homicide,” says Tso. “At a homicide crime scene you get your DNA and you get your witnesses, but when it comes to money laundering and ﬁnancial crimes, they cross through international borders, you’ve got complex corporate structures and you need forensic auditing skills to follow very sophisticated paper trails.”

The ﬁght against money laundering in B.C. suffered a major setback late last year when federal prosecutors stayed criminal charges related to the RCMP’s “E-Pirate” investigation. The trial against Silver International Investments, Caixuan Qin and Jian Jun Zhu, which included allegations that $220 million in suspected drug cash was laundered through an underground bank and casino in one year, was to have begun in April. Media later reported the charges were stayed after prosecutors mistakenly exposed a police informant. “That was to be Canada’s largest money laundering case in history,” Eby said recently at a conference focused on Vancouver’s housing market. “To have that collapse on the eve of trial was a very signiﬁcant issue in terms of public conﬁdence in the justice system.”

Provincial prosecutors immediately launched civil forfeiture lawsuits against Qin, Zhu and Silver, alleging money laundering and seeking to recover millions of dollars worth of real estate, casino chips and cash. All three have denied the allegations. A second forfeiture case stemming from the E-Pirate investigation also accuses Stephen Hai Peng Chen of money laundering. He denies the allegations. B.C.’s civil forfeiture ofﬁce is suing him to seize two homes worth a combined $2.7 million, as well as $60,100 in cash, which, ironically enough, police found stuffed in a clothes dryer.

B.C.’s Eby has vowed to create a registry of beneficial owners

The same day the money laundering panel released its report in May, another report initiated by the B.C. government was made public. Written by lawyer and former RCMP deputy commissioner Peter German, “Dirty Money — Part 2” was a follow-up to his 2018 report detailing how for years criminals treated Vancouver-area casinos as unwitting “laundromats” to wash illicit money. After the release of the report, Eby accused the province’s previous Liberal government of “turning a blind eye” to the money laundering activity at B.C. casinos, which German’s latest report delved into more deeply. It also detailed how dirty money winds its way through B.C.’s luxury vehicle market and real estate industry.

On the automobile front, German’s team heard from luxury car dealers who said they were “right in the thick of money laundering here,” with large cash-only sales occurring on a monthly basis. In one case, a young car buyer dropped $200,000 cash on a new car and the dealership dispatched a squad of employees to haul the money to the bank, which, after learning that it came from a luxury car sale, gladly accepted the cash.

German says there’s a key difference between money laundering through casinos or luxury cars and through real estate. “You don’t see people carrying bags of cash with real estate,” he says in an interview, noting that with casinos and car dealers the goal is to get dirty money into the legitimate ﬁnancial system. “With real estate, you’re dealing with money that has already been cleaned.”

The German report identiﬁes several signs of risk for the real estate sector, such as the growth in private mortgage lending, which has thrived in recent years as regulators tightened mortgage rules. In B.C., he found that 90,000 residential mortgages, equal to nine per cent of the market, are held by a mishmash of 18,570 private lenders.

RELATED: Why house prices are unlikely to rise any time soon

Private lending has also been on the rise in Toronto. A report last year from the Bank of Canada determined that private lenders now account for nine per cent of new mortgages in the city, while the Toronto brokerage Realosophy found 20 per cent of reﬁnancings involved private lenders in 2018, up 67 per cent in two years.

That ﬁts with a quick survey Maclean’s conducted with Ben Rabidoux of North Cove Advisors of high-end properties listed for sale in Toronto, Richmond Hill and Markham, Ont. In the case of 90 of the most expensive houses in those three cities, fully one-third were carrying private mortgages, and of those homes, 20 per cent involved multiple private mortgages. In the case of one Richmond Hill home currently listed for more than $7 million, there were eight private mortgages.

It’s not just that private lenders are not regulated like traditional banks. They don’t have to report suspicious transactions to the Financial Transaction and Reports Analysis Centre of Canada (Fintrac), the watchdog tasked with detecting and preventing money laundering and terrorist ﬁnancing. “We have a hopscotch system of ﬁnancial reporting in this country,” says German. Some industries like banking are required to report all transactions over $10,000, while others, like private lenders and lawyers, are exempt.

German says the real estate industry in particular has a deplorable track record when it comes to flagging dubious transactions. From 2014 to 2018, the entire real estate sector in B.C. flagged just 62 suspicious transactions, according to the German report. The numbers in Ontario are hardly better. Over the same period, that province’s real estate industry reported just 112 suspicious transactions, according to ﬁgures provided to Maclean’s, even though Ontario has a population three times larger than that of B.C. Fintrac says it has ramped up real estate investigations in the past two years, conducting 362 examinations nationwide, 37 per cent of which took place in Ontario.

Things may soon get better. The last federal budget included additional funding to improve Fintrac’s examinations in the casino and real estate sectors. A Fintrac spokesperson says the agency will also play a role in a new task force that was proposed in the 2019 federal budget; it’s meant to improve coordination between law enforcement and intelligence agencies to ﬁght money laundering.

But for now, says German, police and Fintrac remain apart. “Fintrac has to guess at what the police want, and police have to guess what’s in the databases,” he says.

Fedeli (right) says Ontario police are ‘well-equipped’ to handle the issue

How bad is Canada at stopping money launderers? “We have a 99.9 per cent failure rate,” says Comeau, the lawyer and activist. He sits on Transparency International’s Canada working group on anti-money laundering and beneﬁcial ownership transparency, and says the most important thing Canada can do to improve its performance is to adopt a national registry of who owns what residential property.

As it stands, Canada makes it incredibly easy for homebuyers, domestic or foreign, to obscure their identities by using numbered companies, offshore trusts and nominee owners to conceal who ultimately owns a house or condominium. That anonymity and opaqueness create a breeding ground for criminal organizations to conceal the flow of proceeds from crime into the housing market. In fact, Comeau believes the B.C. expert panel on money laundering far underestimated the scale of money laundering in Canada at an annual $46.7 billion. He believes the value of the crime is likely closer to $100 billion to $130 billion a year.

B.C. has begun to tackle the problem. In April, Premier Horgan announced the creation of Canada’s ﬁrst public registry of property owners. All corporations, trusts and nominees will have to disclose their beneﬁcial owners. Those that fail to comply will face ﬁnes of up to $100,000 or 15 per cent of the assessed property value, whichever amount is greater. The move will bring the province in line with countries like the United Kingdom, Germany and France that have already established property registries.

In Ontario, realtors are lobbying the province to follow suit. Last month, Tim Hudak, CEO of the Ontario Real Estate Association, said a beneﬁcial ownership registry in Ontario was “well past due,” adding, “Ontario realtors don’t want to see a single dollar of dirty money coming into the housing market. When criminals hide their money here, it drives the price of real estate out of reach for regular Ontarians.”

A recent Transparency International report that examined a decade worth of Toronto real estate transactions found that since 2008, companies acquired $28.4 billion in Toronto-area housing, with most of those being private corporations whose owners were anonymous.

But the B.C. government’s efforts to clamp down on money laundering, not to mention its other measures aimed at cooling the housing market, aren’t going over well with everyone. Speaking to Business in Vancouver, Fraser Institute senior policy analyst Josef Filipowicz warned the moves could hurt the B.C. economy by harming luxury retailers. Fewer big-ticket luxury items sold for cash could lead to slower sales, his argument went, forcing retailers to cut back on staff.

Eby, B.C.’s attorney general, took to Twitter to skewer the idea that money launderers need protecting in order to save jobs. “How about ‘Bullet sales decline could impact gun store jobs if government successfully cracks down on gangs,’ followed by ‘Cancer doctors fear for careers with crackdown on tobacco.’ ”

Joking aside, the animosity toward the government’s recent measures is becoming palpable—at least among certain demographic groups with a history of high voter turnout. Lawyer Jonathan Rubenstein, 70, is director of StepUP, an organization of 2,000 mostly silver-haired members that formed to oppose the NDP’s housing measures. He says the group is for “people who understood that in a society the creation of wealth is very important and that protecting the minorities in that society is very important and not being unduly unfair to these sections of society is very important.” He insists that cracking down on money laundering, which could potentially remove Chinese buyers from the market, is unwarranted, since the numbers being bandied about are theoretical: “We don’t know how much dirty money is in the houses.”

On the other side of the demographic spectrum are young Vancouverites shut out of home-buying by soaring prices, who welcome any measures that remove froth from the market. “For a lot of people my age in the city, owning a home is just not a feasible thing,” says Trevor Clarke, a 28-year-old public relations professional. During the run-up in prices, it was clear to everyone that there was a lot of money coming into the city, he says, “but the justiﬁcation was always—well, Vancouver is a really desirable place, so who are we to say that the money coming in is dirty?

“But it gets to a point where people are just sitting on their homes and using them as investments,” he adds. “My opinion of that has really changed; housing is less of a commodity and more of a basic need that a city should govern and legislate for citizens.”

As B.C. tackles its money laundering crisis, and other provinces look on, those involved in the ﬁght don’t expect any easy victories. “It’s like Medusa’s head,” says Duhaime. “You cut off one and suddenly realize there are 10 other snake heads you need to deal with.”

—with ﬁles from Rachel Jansen

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Money laundering from China into Canada
increasingly used banks and homes after
COVID-19: FINTRAC
With casino closures during the pandemic Canada's financial watchdog observed more wire transfers from Hong Kong into real estate, law firms, securities
Sam Cooper
Aug 07, 2023

Fintrac flow chart shows sophisticated underground banking involving China, Hong Kong and Canada
Fintrac, Canada’s anti-money laundering watchdog, is reporting that underground banking schemes involving Chinese crime groups and Canadian diaspora communities rapidly evolved with casino closures during the pandemic, and sophisticated, professional money launderers are increasingly flooding international wire transfers into banks, law offices and property development in Canada.
Fintrac’s findings raise concerns that Canada’s housing market is being used widely and increasingly in these schemes, and prompt questions about how this criminal activity is impacting prices in the nation’s already overheated real estate.
Fintrac’s new report stems from a study of criminal infiltration of Canadian banks and B.C. government casinos, which prior to 2019, focused on the laundering of bank drafts into casino accounts.
Called Project Athena, the joint-study from Canadian organized crime policing units and Fintrac — which has voluminous financial transaction data across many sectors — found that Chinese transnational crime groups were easily using casinos on Canada’s West Coast.
But Fintrac expanded Project Athena’s scope, the agency says, because investigators discovered China-based crime groups were increasingly penetrating the national economy, laundering funds through Canada’s real estate, securities and stock markets, and automotive industry.
These transactions bring together the interests of transnational criminals seeking to launder drug money collected worldwide, and citizens in diaspora communities, through the use of professional underground banks, which enable people in Canada to import funds from China, skirting Beijing’s strict currency-export controls, through complex schemes that often blend legitimate and illegitimate sources of funds.

Money Laundering in Canada: More unknowns than knowns
Knowledge Base
Dec 2012
Canada has become a well-known target, even a magnet, for money laundering. Ironically once a Canadian has the legal right of ownership, the law firmly protects that right. For that reason laundered money in Canada is much more valuable than dirty money elsewhere. And that is why money launderers are ready to pay well over asking for high-priced real estate, where multimillion-dollar blocks of cash can be cleansed in a single deal. The defining issue of our times must be who will stop these criminal predators from selling opioid, laundering the proceeds, buying up real estate and violating every conceivable aspect of Canadian sovereignty and the Criminal Code. Let’s go deeper into the ‘Rabbit Hole’…..
Escrow accounts are being used in real estate transactions, specifically for the sale of a house. There are no significant regulatory obligations imposed on title or escrow providers (or on attorneys handling transactions) to validate the origin of funds coming through a direct wire from an offshore banking account.
Real estate business and Shell Companies: Snow Washing ?
The term ‘Snow Washing’ is used when it comes to talk about tax evasion and money laundering in Canada. It refers to hiding illegitimate financial transactions often for purposes of tax evasion. Some tax advisers around the world are touting shell companies in Canada to help mask a client’s assets and business dealings. Once the company is formed, banks or other parties in other countries are going to presume that it’s legitimate because it’s Canadian — pure as the driven snow of the Great White North … they are trying to pretend that it’s Canadian when it’s really not. Snow Washing becomes more evident when we come across reports on foreign students with no known income buying homes worth millions of dollars in Vancouver.
Vancouver : City under scrutiny
Vancouver has become a hub for dirty money, tax evasion, and a place to park foreign cash of unknown origin. Casinos for years have been accepting millions in cash often stuffed into suitcases and most recently, a grey market has been developed in Vancouver-to-China luxury car exports that sent millions of dollars in sales-tax refunds to overseas buyers. Millions of dollars are being laundered through Lower Mainland casinos. The amount of money being laundered in British Columbia is more than anyone predicted. In real estate alone, an estimated $5 billion may have been laundered in 2018 in the province. Money laundering from opioids made in the South of China has amounted to billions of dollars in BC alone, which has helped to make home ownership out of reach for most millennials. This is how Vancouver became the world’s laundromat for foreign organized crime. More unknowns will come out if we create an Excel sheet for people living in Vancouver renting exotic cars; living in mansions; flying on private jets; gambling at casinos with huge cash—at least 500 common denominator persons will qualify as high risk ones. Then CRA (Canada Revenue Agency) can check (instead of aiming the sword at people having hard-earned income) if their earning matches spending. Over $ 85 million in GST rebates were issued in 2018 to “luxury” car buyers who are purchasing $ 100, 000 + vehicles in cash or through “3rd parties” to launder drug proceeds as well.
Ontario-Target zone for human trafficking and horse racing
Human trafficking is taking human tolls on all of us. More than two-thirds of police-reported human trafficking violations in Canada occur inside the province. Toronto acted as a hub over past couple of years for a number of human trafficking routes. Now we come to Horse Racing business. This sector is vulnerable to money laundering, but not accountable to any regulatory body to monitor its operations for this type of crime. Although the horse racing industry is licensed, regulated and receives a significant amount of public funding, it lacks transparency and public accountability.

Illicit Cannabis Trading and celebrating 1 year of pot legalization
There are growing indications that the drug trade is increasingly moving to the dark web and crypto currencies. Youngsters are shopping for drugs on the so-called dark net, accessible not through traditional search engines but by way of special browsers and software that conceal IP addresses and make users harder to trace. These drug markets are clandestine dispensaries of illicit and dangerous substances that are sold in exchange for cryptocurrencies, such as bitcoin. They pose a challenging front in the fight against the opioid crisis for the law enforcing agencies. Time is ripe enough (on Financial Institutions’ part) to gain the visibility and expertise to mitigate risk exposure from this new asset class. Statistics say, illicit sales of cannabis alone would add around 0.4% to its GDP.
‘The Laundromat’: The movie
The movie ‘The Laundromat’ is about a big law firm called Mossack Fonseca that was based in Panama.90% of its clients were big law firms and accounting firms in Germany, Canada, Hong Kong, China, the UK who were asking them to create shell and shelf companies. Historically, gatekeepers have always remained at focal point because of such services. It is believed, one of China’s most Politically Exposed Persons ever, whose father has been given a life sentence in 2013 and is now in a Chinese prison (seems to have been featured in the movie ‘The Laundromat’), is working as a business analyst for a Canadian company with deep China ties.
Blockchain Technology: Unavoidable reality
Crypto assets have become pervasive in the financial industry across the globe to a surprising degree. Consequently, even banks that don’t think they have risk exposure, need early warnings and detection of bad actors operating in their networks and payment system. When we think about cryptocurrencies, we see, British Columbia based LifeLabs paid Bitcoin to hacker extorting them, which they are allowed to do only if exchange files an SAR (Suspicious Activity Reporting) on LifeLabs and hacker. It is high time to gain the visibility and expertise to mitigate risk exposure from this new asset class.
FINTRAC: Coming out of the image ‘toothless crime watchdog’
FINTRAC, being Canada’s financial intelligence unit, mandates 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. Specifically, through introduction of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC aims to assist in fulfilling Canada’s international commitments to participate in the fight against transnational crime, particularly money laundering and the fight against terrorist activities. Recently, FINTRAC published certain changes to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and from now on FINTRAC is required to publicly name the reporting entity, the nature of its violation of the PCMLTFA, and the amount of the penalty imposed. FINTRAC is highly focusing on unregistered Money Service Businesses in Canada. FINTRAC’s investigation identified that cannabis dispensaries not federally licensed to produce and/or sell cannabis in Canada, used Moxipay (an Edmonton based Money Service Business, operating as an unregistered Money Service Business) to transfer and receive funds. FINTRAC provides intelligence on the money trail to law enforcement and the national security agencies—with information not readily available elsewhere. Where this information is not presented by reporting entities to FINTRAC in a form required, stiff penalties including making public all administrative monetary penalties (AMPs), can be imposed. These AMPs will range between $25,000 to $500,000 depending on the level of deficiencies. Organizations can, therefore, suffer irreparable reputational damage if found to be deficient in this regard.
Journey towards infinity : Are we ready ?
Money laundering in Canada is nearly impossible to quantify because, by nature, it’s hidden. However, Canada has fallen so far behind for so many years, it’s not that easy to catch-up. In terms of financial crime compliance in Canada, we are not doing bad nationally on anti-money laundering; not doing great on counter-terrorist financing. It’s critical to understand that the landscape is changing on two frontiers. One is the regulatory frontier, and the other is the environment in which we operate. Bad actors/wrongdoers are changing their ways every single day. Positive thing is, Canada’s regulatory authorities are much more concerned about this issue now. Better late than never. It’s heartening to note, tone from the top is already there. Ontario is investing $20M into fighting human trafficking. Steps have already been taken by the Federal and Provincial government to create mass awareness against this atrocity, a 24/7 Hotline has been launched to report any suspicious activities relating to human trafficking. As British Columbia begins to crack down on the washing of dirty money, failure to change and implement national laws will make the crime go elsewhere in the country. Let’s keep our fingers crossed and wait to see what lies ahead of us.

Canada.ca
FINTRAC
Strategic Intelligence
Updated indicators: Laundering
the proceeds of crime through
underground banking schemes
Reference number: FINTRAC-2023-OA002
July 2023
Updated indicators: Laundering the proceeds of crime through underground banking schemes (PDF version, 731 kb)
Purpose
This Operational Alert updates FINTRAC’s 2019 Project Athena Operational Alert Laundering the proceeds of crime through a casino-related underground banking scheme. It lists additional indicators to assist reporting entities in recognizing financial transactions suspected of being related to the laundering of proceeds of crime with roots in underground banking related to China, notably in Hong Kong. Through financial transaction reports, FINTRAC is able to facilitate the detection, prevention and deterrence of all stages of money laundering (placement, layering and integration) and the financing of terrorist activities by providing actionable financial intelligence disclosures to law enforcement and national security agencies.
Project Athena
A public-private partnership in collaboration with the Combined Forces Special Enforcement Unit – British Columbia and supported by FINTRAC. First launched in 2019, Project Athena focuses on improving the collective understanding of the money laundering threat, strengthen financial systems and controls, and disrupt money laundering activity in British Columbia and across Canada.

Background

Underground banking refers to banking activities that run parallel to and operate outside of the formal banking system, commonly in the form of 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. The final settlement between brokers occurs through the exchange of cash, trade or by other means. Informal value transfer systems are regulated under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act but are often successfully exploited in an effort to evade sanctions, state currency control restrictions through capital flight, or to facilitate criminal activities such as professional money laundering (see FINTRAC’s Sectorial and Geographic Advisory on Underground Banking for a comprehensive perspective). For the purposes of this Operational Alert, underground banking refers to the criminal abuse of the informal value transfer sector to launder the proceeds of crime.
Underground banking and the formal banking system inevitably intersect as certain transactions demand the use of the formal banking system, such as the purchase of financial instruments used to launder funds through various sectors such as the real estate or automotive industries. It is at this stage where underground banking is partially observed by regulated financial institutions and becomes subject to FINTRAC reporting obligations.
Given the focus of Project Athena on links to China, notably in Hong Kong, the indicators in this Operational Alert reflect underground banking activities suspected of being tied to China-linked money laundering organizations. The prominence of China, notably Hong Kong, in the indicators is a result of professional money launderers exploiting efforts by the Chinese diaspora in Canada to circumvent currency control restrictions to access their funds outside of that country. Hong Kong provides a key geographic risk as a transition point for China-based transactions into international underground banking schemes given that, as a Special Administrative Region, Hong Kong is excluded from the currency controls in place for the rest of China. Although not all funds entering Canada from China are necessarily avoiding Chinese currency control restrictions, nor is the circumvention of these controls in itself a crime in Canada, the currency control restrictions create black market opportunities for professional money launderers to launder proceeds of crime.
Figure 1 illustrates one method of informal value transfer systems that the Chinese-Canadian diaspora may use to move their funds from China/Hong Kong to Canada. Funds are transferred to the bank/credit union accounts of multiple, unrelated individuals in Canada, by means of foreign money service businesses (MSBs). This mechanism provides professional money launderers with a potential supply of money mulesFootnote1 who can receive deposits of cash sourced from the professional money launderers’ criminal clients, following a transfer of the customers’ funds held in China. Transactions from informal value transfer systems simultaneously facilitates money laundering and the circumvention of Chinese currency controls.
Evolution of Project Athena
Project Athena, a public-private partnership focused on combatting money laundering in Canada, initially began as a Combined Forces Special Enforcement Unit – British Columbia probe into the use of bank drafts at casinos in Lower Mainland, British Columbia. As money laundering was also observed to be taking place beyond the casino sector, Project Athena’s scope expanded to a national level and includes other sectors such as real estate, securities, and automotive.
Casino-related underground banking transactions showed a continuation of the same activity highlighted in the 2019 Operational Alert on laundering the proceeds of crime through a casino-related underground banking scheme. However, as a result of the temporary closures of Canadian casinos due to the COVID-19 pandemic, professional money launderers began to diversify their money laundering methods. During this time, FINTRAC observed a rise in money laundering typologies involving transferring large sums of funds to Canada from foreign money services businesses, often located in China, notably Hong Kong, and the laundering of the funds primarily through the real estate, securities, automotive and the legal professions. FINTRAC also observed a resurgence of casino transactions when casinos re-opened in between the pandemic-related temporary closures. Therefore, FINTRAC’s indicators on casino-related transactions remain relevant.
Overview of FINTRAC’s analysis of disclosures related to laundering the proceeds of crime through an underground banking scheme
FINTRAC analyzed a sample of nearly 48,000 transactions in relation to the laundering of the proceeds of crime through underground banking schemes. The majority of the underground banking-related disclosures primarily involved incoming wire transfers from entities or individuals in China, notably in Hong Kong, followed by the movement of these funds through financial institutions into the following sectors: casinos, real estate, securities, automotive and the legal profession. There were instances of crossover between these sectors. Overall, electronic funds transfers, email money transfers, cash deposits, and bank drafts were the primary transaction types used in underground banking-related disclosures. Additionally, FINTRAC observed the frequent layering of funds between related accounts and the use of investment accounts to launder funds.
Commonly listed occupations for individuals involved in disclosures related to underground banking schemes included students; homemakers; office managers; business owners/CEOs (frequently listed within the automotive industry, construction/property development and securities firms); real estate agents; and unemployed. FINTRAC notes that it is possible that many of these individuals reported in suspicious transactions involving Project Athena with a listed occupation of student, homemaker, office manager and unemployed were used as money mules. These individuals also operated as “straw buyers”Footnote2, purchasing assets with funds received from individuals or entities in China, notably Hong Kong. Additionally, these individuals may also service Asian “daigou”Footnote3 networks by buying high demand goods on behalf of clients in China. Although not illegal, “daigou” networks, by their nature, obscure both the identity of the client and source of funds, which creates an effective mechanism to integrate illicit cash into Chinese underground banking. Differentiating between entrepreneurial activity and money laundering in “daigou” networks may be challenging.
Use of money mules
The bank accounts of suspected money mules demonstrated in-and-out activity, with a high volume of cash deposits or large incoming wire transfers from parties located in China, notably in Hong Kong, whose relationship is unknown. These funds were then used to purchase bank drafts payable to individuals and/or entities listed in the following sectors: real estate, securities, automotive and the legal profession.
Misuse of real estate
Funds going through the real estate sector were sent to individuals involved in property management, real estate development, real estate agents, sellers, brokers, real estate consultants, mortgage brokers, and individuals who own any of these types of businesses. Often, incoming funds from China, notably in Hong Kong, were used to fund a series of structured draft purchases to a property developer with memos referencing the same address or a series of unit numbers within the same address.
Misuse of securities
Investment firms, along with individuals listed as financial planners and investors, were often the recipient of large bank drafts ultimately funded from unknown sources in China, notably in Hong Kong. Additionally, individuals receiving wires from parties located in these jurisdictions used the funds to purchase short-term investment products such as a Guaranteed Investment Certificates. These Guaranteed Investment Certificates would then be redeemed shortly after, incurring early redemption penalties, and the funds would be transferred to other client accounts, or used to purchase bank drafts payable to either the client or related individuals.
Misuse of automotive industry
Transactions involving the automotive sector included car dealerships, particularly high-end car dealerships or used car dealerships, automotive-related import/export entities, and owners of such businesses. Individuals, operating as suspected “straw buyers”, used funds received from individuals or entities located in China, notably Hong Kong, to fund bank drafts to purchase from high-end car dealerships. These purchases were often inconsistent with stated occupation of the purchasing client, such as student or homemaker. Additionally, FINTRAC observed a circular flow of funds between different entities listed as used car dealerships and import/export entities, with one or more entities located in China, notably in Hong Kong.
Misuse of the legal profession
Legal professionals, such as individual lawyers, law firms and notaries, are inherently vulnerable, wittingly or unwittingly, to exploitation for money laundering and terrorist financing given that the identity of originating conductors and ultimate beneficiaries involved in financial transactions, as well as the purpose of the funds, may be legally withheld. Methods commonly exploited to launder proceeds of crime include the misuse of client accounts, purchase of property, creation and management of trusts and companies, and managing client affairsFootnote4. FINTRAC observed several instances of legal professionals specializing in real estate listed as the beneficiary of bank drafts and less frequently cheques sourced from an unknown source in China, notably in Hong Kong. Once the draft is sent, no further financial transactions relating to the purchase or maintenance of a property are observed in the bank account of the sending client.
Reasonable ground to suspect and how to use indicators
How reporting entities determine if they should submit a suspicious transaction report to FINTRAC (for either a completed or an attempted financial transaction) requires more than a “gut feel” or “hunch,” although proof of money laundering is not required. Reporting entities are to consider the facts, context and money laundering indicators of a transaction. When these elements are viewed together, they create a picture that is essential to differentiate between what may be suspicious and what may be reasonable in a given scenario. Reporting entities must reach grounds to suspect that a transaction is related to the laundering or attempted laundering of proceeds or crime before they can submit a suspicious transaction report to FINTRAC.
Indicators of money laundering can be thought of as red flags indicating that something may very well be wrong. Red flags typically stem from one or more characteristics, behaviours, patterns, and other contextual factors related to financial transactions that make them appear inconsistent with what is expected or considered normal. On its own, an indicator may not initially appear suspicious. However, it could lead you to question the legitimacy of a transaction. This may prompt you to assess the transaction to determine whether there are further facts, contextual elements or additional money laundering or terrorist activity financing indicators, that would increase your suspicion and submit a suspicious transaction report to FINTRAC (see Reporting suspicious transactions to FINTRAC).
Money laundering indicators
Below are additional money laundering indicators related to the laundering of the proceeds of crime through China, notably in Hong Kong, on underground banking schemes derived from FINTRAC’s analysis. They reflect the types and patterns of transactions, contextual factors and those that emphasize the importance of knowing your client. All indicators from FINTRAC’s 2019 Operational Alert on laundering the proceeds of crime through a casino-related underground banking scheme remain relevant. The following additional indicators should be considered in addition to those in the 2019 Operational Alert.
These indicators should not be treated in isolation; on their own, they may not be indicative of money laundering or other suspicious activity. They should be assessed by reporting entities in combination with what they know about their client and other factors surrounding the transaction to determine if there are reasonable grounds to suspect that a transaction or attempted transaction is related to the commission or attempted commission of a money laundering offence. Several indicators may reveal unknown links that, taken together, could lead to reasonable grounds to suspect that the transaction is related to the laundering of proceeds derived from underground banking schemes. It is a constellation of factors that strengthen the determination of suspicion. These indicators aim to help reporting entities in their analysis and assessment of suspicious financial transactions.
General
Client moves funds sourced from individuals/entities located in China, notably in Hong Kong, within a short period of time to one or more of the following sectors: real estate, investments, automotive and/or the legal profession.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are immediately transferred to a client’s associated personal or businesses account(s) or to unrelated party(ies).
Client has ties to China and is using their accounts for pass-through activities funded by individuals/entities located in China, notably in Hong Kong, whose relationship is unclear.
Client is receiving funds from entities located in China, notably in Hong Kong, that are connected to the money service business industry, with no ultimate remitting party names listed.
Funds are received from entities in China, notably in Hong Kong, with limited to no online presence and there are no details relating to the types of services offered by the sending entity.
Stated purpose of incoming funds from individuals/entities located in China, notably in Hong Kong, is for the purchase of property but the funds were used to purchase Guaranteed Investment Certificates.
Business accounts are funded by multiple transfers, mainly from the business’ directors and/or authorized signatories’ personal accounts.
Adverse media mentions client, or related transacting parties of the client, as being linked to criminal activity such as fraud, possession of proceeds of crime, corruption/bribery, or illicit gambling/betting charges.
Real estate
Incoming funds of unknown origin sent by individuals/entities located in China, notably in Hong Kong, to a real estate-related party (e.g., real estate agent/brokerage or real estate developer) in structured amounts with indications suggesting the purpose of funds is for a real estate-related transaction (such as memos referencing an address).
Cash deposit(s) are followed by funds sent to a real estate party (e.g., real estate agent/brokerage) with indications suggesting the purpose of payment is for a real estate-related transaction (such as memos referencing the same address repeatedly).
Client receives funds from individuals/entities located in China, notably in Hong Kong, marked for education or personal purposes (e.g., “tuition” or “living expense”), but funds are then used towards payments with indications suggesting the purpose of payment is for a real estate-related transaction (such as memos referencing “property purchase” or “mortgage”).
Mortgage payments are sourced from incoming funds from China, notably in Hong Kong, where the original source of funds is unclear.
Securities
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to purchase shorter-term investment products (such as Guaranteed Investment Certificates), which are then redeemed before the term date, despite incurring a penalty.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are quickly transferred to holding companies, trust companies or investment firms.
Cash deposits are transferred within a short period of time to a holding company, trust company or investment firm.
Automotive
Cash deposits are transferred within a short period of time to vehicle import/export companies, often located in China, notably in Hong Kong.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds to high end car dealerships that are inconsistent with clients stated occupation.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds to entities listed in the automotive sector who have newer profiles (1-2 years at most).
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds to entities listed in the automotive sector who have residential addresses as their business locations.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds to entities listed in the automotive sector who have limited to no online presence.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds in a similar amount to a car dealership.
Circular flow of funds between different entities listed in the automotive industry and import/export entities, with one or more entity located in China, notably in Hong Kong.
Outgoing fund transfers to entities operating in China, notably in Hong Kong, with references to the automotive industry (such as “car purchases” or “buying cars”) that are inconsistent with client’s stated occupation (e.g., student, homemaker or unemployed).
Inter-account transfer from personal to business accounts (or vice-versa) sourced through high value domestic fund transfers from individuals/entities in the automotive sector.
Client receiving funds from entities with no apparent online presence that appear to be involved in automotive import/export activities and are inconsistent with clients stated occupation or expected pattern of activities (e.g., student, homemaker, unemployed).
Legal profession
Incoming funds of unknown origin from individuals/entities located in China, notably in Hong Kong, are sent to a legal professional in structured amounts with no clear relationship or stated purpose.
Incoming funds from individuals/entities located in China, notably in Hong Kong, are used to send funds to legal professionals who specialize in real estate and are inconsistent with client’s stated occupation or expected pattern of activities (e.g., student, homemaker, unemployed).
Client’s account is mainly or in part funded by bank drafts, email money transfers and/or cheques from legal professionals who have limited or no open source footprint.
Cash deposits, not in line with account holder’s stated occupation, were used to send funds to legal professionals with no clear relationship.
Financial transactions such as cash deposits/withdrawals, use of personal negotiable instruments (e.g., cheques), electronic funds transfers and foreign exchange using legal professional’s personal account.
Reporting to FINTRAC
To facilitate FINTRAC’s disclosure process, please include the term #ProjectAthena or #Athena in Part G-Description of suspicious activity on the suspicious transaction report. See also, Reporting suspicious transactions to FINTRAC to FINTRAC.
Contact FINTRAC
Email: guidelines-lignesdirectrices@fintrac-canafe.gc.ca
Telephone: 1-866-346-8722 (toll-free)
Facsimile: 613-943-7931
Mail: FINTRAC, 24th Floor, 234 Laurier Avenue West, Ottawa ON K1P 1H7, Canada
© His Majesty the King in Right of Canada, 2023.
Cat. No. FD4-32/2023E-PDF
ISBN 978-0-660-49479-1
Resources
Several other FINTRAC and external reports also describe the contextual and financial aspects of underground banking. For more information on underground banking, as well as associated financial intelligence, please consult the following resources:
Canada
FINTRAC: Underground Banking through Unregistered Money Services Businesses
FINTRAC: Professional money laundering through trade and money services businesses
Department of Finance Canada: Updated Assessment of Inherent Risks of Money Laundering and Terrorist Financing in Canada
International
AUSTRAC: Strategic analysis brief: Money laundering through real estate
Financial Action Task Force: Money Laundering & Terrorist Financing Through the Real Estate Sector
Financial Action Task Force: Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals
Financial Action Task Force: Professional Money Laundering
Financial Action Task Force: The Role of Hawala and other Similar Service Providers in Money Laundering and Terrorist Financing
Footnote 1
Money mules refers to an individual who, wittingly or unwittingly, transfers or transports proceeds of crime on behalf of a criminal organization or money launderer.
Return to footnote1
Footnote 2
A “straw buyer” refers to an individual who acts as an intermediary in place of the true purchaser of an asset in order to conceal ownership.
Return to footnote2
Footnote 3
National Crime Agency Chinese Underground Banking and ‘Daigou’
Return to footnote3
Footnote 4
Financial Action Task Force Money Laundering and Terrorist Financing Vulnerabilities of Legal Professionals

Friday, October 31, 2025