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Report on the effectiveness of anti-money laundering and counter terrorist financing measures and help develop better detection and deterrence methods. Unless indicated otherwise, the analyses and observations in this report are based on the analysis of financial transaction reports, and voluntary information reports available to FINTRAC. Readers should also keep in mind that subsection 58(2) of the Act prohibits FINTRAC from including information in its strategic financial intelligence products that could be used to directly or indirectly identify individuals who provided a report or information to the Centre, or other persons or entities about whom or about which a report or information was provided. Mass marketing fraud is a crime that results in substantial losses to individuals in Canada and in many other countries. Mass marketing fraud operations make considerable use of businesses to launder illicit proceeds. Businesses in the automotive sector, one of the main sectors suspected to be used to launder the proceeds of mass marketing fraud, have used trade-based money laundering techniques to launder funds.
The analysis focused primarily on describing the techniques and methods used to launder the proceeds of mass marketing fraud. Mass marketing fraud is defined as fraud committed through mass media communications, such as the Internet, telephone, mail, fax or print. The victims of mass marketing fraud are mostly found in North American and other Western countries. As in Canada, it is difficult to estimate the international financial losses from mass marketing fraud because a large proportion of cases are not reported to the authorities. The merchandise category of mass marketing fraud includes any product purchased through a classified ad, over the Internet, on an Internet auction site, by catalogue, by mail order, which was never received, was of inferior value, or was not as advertised.
From the perspective of reporting entities, the proceeds from this type of mass marketing fraud likely appear legitimate (much more so than for other types of mass marketing fraud), as they appear to be transactions between two commercial entities. Approximately 70% of electronic funds transfers to Canada associated with this category of fraud came from the United States, while the remainder came mainly from Europe and the Caribbean. The prize category of mass marketing fraud includes any false, deceptive or misleading solicitation advising people that they have won or have a chance to win something, but are required to make a purchase or pay an advance fee, such as taxes, to receive the prize. Information from law enforcement and some financial transaction reports show that the proceeds of the "sweepstakes fraud", usually in amounts under $100, are sent to the suspected fraud perpetrators mainly in the form of cheques, while the proceeds of "tax on lottery winnings," varying from a few hundred to tens of thousands of dollars, are sent via electronic funds transfers to bank accounts or money service businesses.
Nearly 60% of electronic funds transfers to Canada associated with this category of mass marketing fraud came from European countries, while only 20% came from the United States. The "emergency" category of mass marketing fraud, which is sometimes referred to as the "Grandparent Scam," includes any solicitation from someone claiming to be a friend or family member saying that he or she is in some kind of trouble. Information provided to FINTRAC by law enforcement, as well as certain financial transaction reports show that the "emergency" mass marketing fraud primarily targets the elderly and usually involves smaller amounts of money varying from a few hundred to a few thousand dollars. Approximately 30% of "emergency" mass marketing fraud-related electronic funds transfers to Canada come from the Middle East, 40% from Europe, and 15% from the United States. Information from law enforcement and some financial transaction reports show that "foreign money offer" mass marketing fraud usually involves sums of money varying from a few thousand to tens of thousands of dollars with victims being found in a broad range of population segments.
Approximately 30% of "foreign money offer" mass marketing fraud-related electronic funds transfers to Canada came from the United States, 25% from Japan and 20% from European countries.
Analysis indicates that nearly 80% of the categories of mass marketing fraud identified fell into the "prize," "merchandise and services" and "foreign money offer" categories.Footnote 18 The categories of mass marketing fraud were identified primarily on the basis of the information included in voluntary information records from law enforcement, although in some cases, suspicious transaction reports were also used.
Financial transaction reports and information provided by law enforcement to FINTRAC indicate that Ontario and Quebec are the bases of operations for most (73%) mass marketing fraud cases (see figure 1).Footnote 19 Analysis also revealed that in 93% of cases, the main base of operations for the scheme was located in the greater metropolitan areas of Toronto, Montreal, Vancouver, Calgary or Edmonton. Analysis of law enforcement information, suspicious transaction reports and electronic funds transfer reports led to the identification of the places of residence of suspected mass marketing fraud victims.
Figures 3 and 4 show the relative distribution of cases by mass marketing fraud category and the relative distribution of the total dollar value of the cases by category, respectively.
We can observe that the relative dollar value of "foreign money offer" and "emergency" categories of mass marketing fraud cases is very low compared to their relative proportion of mass marketing fraud cases. The following section describes the techniques and methods that appear to be used to launder the proceeds of suspected mass marketing fraud, as observed in the financial transaction reports available to FINTRAC.
Amongst the observed methods and techniques, the use of businesses was the most frequently observed, accounting for 25% of total identified techniques and methods. Businesses can comingle the proceeds of fraud with the proceeds of legitimate business activities. Businesses operating in the automotive sector have been found to use trade-based money laundering techniques to launder the proceeds of mass marketing fraud.
This sanitized case represents a "foreign money offer" mass marketing fraud scheme where the victims are asked to deposit a cheque and wire funds to a bank account in an Asian country for a commission. Analysis of information provided to FINTRAC by law enforcement suggests that the telemarketing and financial sectors are closely associated with the "merchandise and services" category of mass marketing fraud. This sanitized case provides an example of the "merchandise and services" mass marketing fraud which targets businesses using boiler room strategies to coerce victims into purchasing overpriced supplies or settling a bill for an item or a service that was not delivered.
Analysis of financial transaction reports, as well as information provided to FINTRAC by law enforcement suggests that businesses, operating as telemarketing firms and call centres, are used to both commit fraud and to launder the resulting proceeds.
Receipt of electronic funds transfers into a business account followed by one or more electronic funds transfers to the country from which the wire payments initially originated. Financial transaction reports show that individuals suspected of involvement in mass marketing fraud make considerable use of money service businesses not only to perpetrate the fraud, but also to launder their illicit proceeds. Structuring implies that a transaction involving cash or other monetary instruments issued by a bank or a money service business is divided into several smaller transactions to avoid raising suspicion.
Structuring is especially prevalent with the "tax on lottery winnings" sub-category and the "foreign money offer" category of mass marketing fraud. The "use of a nominee" is a method where an actual or fictitious person who is not associated with the fraud carries out a financial transaction on behalf of a suspected mass marketing fraud perpetrator. Individuals' receiving several small electronic funds transfers from the one person or a group of persons over a short time period. The above sanitized case represents a "tax on lottery winnings" mass marketing fraud scheme that involves fraudulent solicitation letters notifying recipients that they have won a lottery, but are first required to pay an advance fee to receive the prize. Through analysis of suspicious transaction reports, FINTRAC has observed that electronic funds transfers from suspected victims are received through various money service businesses by multiple suspected mass marketing fraud perpetrators in the form of cash.
Mass marketing fraud is a crime which is growing in scope and one that incurs substantial losses to victims worldwide, including Canadians.
Several categories of mass marketing fraud exist, each with particular characteristics designed to defraud victims. The money laundering methods and techniques described in this report will continue to be employed by criminals as long as they are successful. Foreign money offer: Any solicitation requesting assistance to transfer a large sum of money from another country. Prize: Any false, deceptive or misleading solicitation advising victims they have won or have the chance to win something but are required to purchase something first or pay an advance fee, such as taxes, to receive the prize. Return to footnote 1 For the purpose of this report all references to mass marketing fraud, related victims and money laundering are based on the investigations of foreign and domestic law enforcement agencies.
Large cash transaction reports (LCTRs): Reporting entities must report all large cash transactions including the receipt of an amount in cash of $10,000 or more within a 24-hour period. Suspicious transaction reports (STRs) and attempted suspicious transaction reports (A-STRs): Reporting entities have to report completed or attempted transactions if there are reasonable grounds to suspect that the transactions are related to the commission or attempted commission of a money laundering offence or a terrorist activity financing offence.
Electronic fund transfers (EFTs): Wire transfers of $10,000 or more that reporting entities receive from abroad or send outside Canada. Return to footnote 4 A single category of mass marketing fraud was used to identify each case in the sample.


Return to footnote 5 "Money Laundering Trends and Typologies in the Canadian Securities Sector." April, 2013.
Return to footnote 6 Mass Marketing Fraud and ID Theft Activities, Canadian Anti-Fraud Centre Criminal Intelligence Analytical Unit, Annual Statistical Report, 2012.
Return to footnote 13 US Federal Trade Commission, Consumer Sentinel Network Data Book for January-December 2009.
Return to footnote 14 The observation that major losses are incurred by businesses may be related to the type of voluntary information record submitted to FINTRAC by law enforcement agencies. Return to footnote 15 A boiler room refers to an outbound call centre which uses deceptive, misleading or fraudulent sales tactics.
Return to footnote 18 Each case in the sample was attributed to a single mass marketing fraud category (mass marketing fraud categories are mutually exclusive). Return to footnote 19 Although for most of the cases analysed it is possible to determine the main province of operation of the fraud with some degree of certainty, in a small number of cases the type of information available did not help to identify a single province of operations. Return to footnote 20 Mass Marketing Fraud and ID Theft Activities, Canadian Anti-Fraud Centre Criminal Intelligence Analytical Unit, Annual Statistical Report, 2013. Return to footnote 21 The automotive sector includes the sale of used cars (the most common activity in the category), short-term leasing, importing and exporting, sales of parts, and servicing. Return to footnote 22 More specifically, the automotive sector uses cash for the sale of used cars, the sale of parts, and automotive repair and maintenance. Return to footnote 23 Financial transactions and reports as well as the voluntary information records shows that the "prize" and "sweepstakes fraud" mass marketing fraud targets individuals in a wide range of jurisdictions. The analysis also revealed that in nearly all cases, the mass marketing fraud operated primarily from an urban area. It has also been observed that considerable use appears to be made of money services businesses, not only to receive funds from victims, but to launder mass marketing fraud proceeds. It should be noted that this report primarily uses the Canadian Anti-Fraud Centre's terminology to describe the categories of mass marketing fraud (see Appendix A).Footnote 4 However, certain categories of mass marketing fraud (such as "job," "loan" and "sale of merchandise by complainant") were not well represented in the sample.
In Canada, the Competition Act prohibits materially false or misleading representations in the promotion of a product or a business interest during person-to-person telephone calls.
According to the Canadian Anti-Fraud Centre, total reported losses in 2012 were more than $76 million.Footnote 6 While the number of mass marketing fraud complaints and victims is decreasing, the value of reported losses is increasing both in Canada and abroad.
However, mass marketing fraud is becoming increasingly international because the growing middle class in several parts of the world is creating an expanding pool of potential victims.
Similarly, in the case of services, it includes any false, deceptive or misleading promotion or solicitation for services such as telecommunications, Internet, financial services, medical services or utilities. Information from law enforcement, as well as information included in suspicious transaction and electronic funds transfer reports indicated that the funds obtained from victimized businesses are mainly in the form of cheques, credit card payments and electronic funds transfers, which corresponds to what may be expected in the case of a fraud primarily targeting businesses. The United States was the destination for over 50% of mass marketing fraud-related electronic funds transfers from Canada, while European countries accounted for most of the rest. Based on the financial transaction reports and the voluntary information records available to FINTRAC, it is possible to identify two sub-categories of this type of fraud.
Law enforcement information and some financial transaction reports show that victims of both of these sub-categories usually reside in the United States or Europe. The United States was the destination of 70% of mass marketing fraud-related electronic funds transfers from Canada, with Europeans and Asian countries accounting for most of the remainder. Usually he or she has been arrested, involved in a car accident or trapped in a foreign country, and needs money immediately for bail, medical fees or a ticket home. This category of mass marketing fraud makes considerable use of money service businesses to receive electronic funds transfers from victims, but also uses banks. The United States was the destination of 60% of electronic funds transfers from Canada, while Asian countries accounted for 30%. The solicitation may also come from an individual claiming to be a lawyer notifying the victim of an inheritance of a sum of money.
The United States was the destination of approximately 30% of EFTs from Canada, Asian countries accounted for 30%, and Middle Eastern countries accounted for 30%. Figure 2 shows that 76% of the mass marketing fraud victims live outside Canada, including a high percentage (66%) living in the United States. The figures illustrate that the "prize" mass marketing fraud category accounts for largest proportion of mass marketing fraud cases (34%), while the "merchandise and services" category of mass marketing fraud accounts for the largest proportion of dollar value of mass marketing fraud cases.
These differences in the relative distribution of mass marketing fraud case categories and of the dollar value of cases by category may be an indication of the "intensity" of the fraud (in terms of potential losses incurred by the victims) for the various categories of mass marketing fraud. For the purpose of this report, they are defined as real or fictitious entities that are controlled by suspected marketing fraud perpetrators and whose activities consist partially or fully in operating a mass marketing fraud scheme or in laundering the proceeds of the fraud.
There are few barriers to entry and it is easy to start a business in either sector, as they are subjected to few regulations. Trade-based money laundering is defined as a process of disguising the proceeds of crime through the use of trade transactions in an attempt to legitimize their illicit origins.
The victims were instructed to deposit the cheque (which will turn out to have non-sufficient funds), take a 10% commission, and send the balance (90% of the amount) by electronic funds transfer to a bank account in an Asian country. The two sectors, which are consistent with the mass marketing fraud modus operandi, account for nearly 35% of the types of businesses observed in this category.
Victims pay by cheque or credit card and the funds are then deposited into business accounts before being sent to other businesses by wire transfer.
Structuring is also used to avoid the $10,000 reporting threshold applicable to large cash transaction reports and electronic funds transfer reports.
The large cash transaction reports and suspicious transaction reports show that the funds received from victims through money service businesses are usually redeemed in cash (or occasionally with other monetary instruments) by the suspected mass marketing fraud perpetrators or their suspected accomplices and then structured into small amounts to be deposited in bank accounts. The nominee is used to dissociate the suspected perpetrator from the proceeds of the fraud, thus concealing the source or true ownership of the funds being issued, deposited or moved. This example shows the combined use of money service businesses and structuring for the purpose of laundering the proceeds of mass marketing fraud. Suspicious transaction reports then show different suspected mass marketing fraud perpetrators (although occasionally, one individual can be seen receiving and sending funds) depositing cash in bank accounts and ordering multiple electronic funds transfers under $10,000 through different money service businesses within a short period of time. Where fraud operations of this type are based in Canada, they appear to be based in urban centres in Ontario and Quebec; FINTRAC data suggests that residents of the United States are a significant target of these operations. Almost all of the cases analysed for this report involved businesses, and the automotive sector is one of the main sectors suspected of being used to launder the proceeds of mass marketing fraud. Mass marketing fraud continually reinvents itself in order to adjust to increased public and reporting sector awareness, as well as law enforcement efforts to combat it. The solicitation may also come from an individual claiming to be a lawyer notifying the victim of the inheritance of a sum of money.
These solicitations involve third parties that commonly make offers for telecommunication, Internet, finance, medical and utility services. Information regarding these investigations and related suspicions have been voluntarily provided to FINTRAC by Canadian police services and foreign financial intelligence units (voluntary information records). Large-scale mass marketing fraud operations (identified in the analysed data) tend to include activities targeting businesses. These cases concern Quebec and Ontario only and were identified as belonging to the "Quebec and Ontario" category. The food sector includes retail and wholesale sale of food products, catering and restaurants. The proceeds of this fraud are therefore received in the form of cheques in various currencies from victims around the world.


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FINTRAC does not have an investigative mandate allowing it to corroborate the suspicions expressed by third parties. These observations are consistent with the Canadian Anti-Fraud Centre's statistics which indicates that Ontario, and primarily the Greater Toronto Area, is the most important area of mass marketing fraud operations in Canada.
Therefore, these categories of mass marketing fraud were included under the "other" category, in the same way that the "merchandise" and "services" categories were combined to create the "merchandise and services" category. Reported losses represent a fraction of the actual losses, because mass marketing fraud is under reported. Additionally, this category may include offers to purchase extended warranties, insurance and sales services. Suspected perpetrators of this type of mass marketing fraud made very little use of money services businesses and cash; the financial transaction reports available to FINTRAC show that the perpetrators made greater use of commercial bank accounts, compared to other categories of mass marketing fraud, which is expected in the context of transactions between businesses. The "sweepstakes fraud" sub-category consists of sending fraudulent mass mailings that target a large number of consumers stating that the recipient must pay a relatively small sum of money to collect a prize.
Victims of "tax on lottery winnings" appear to be mostly seniors, while victims of the "sweepstakes fraud" appear to be found in a broader range of population segments. Large cash transaction reports and suspicious transaction reports show that when received through money service businesses, the proceeds of the fraud are mainly withdrawn as cash and later deposited into business or personal accounts.
However, proceeds of mass marketing fraud may also be laundered with instruments or using transactions that cannot be observed by FINTRAC. In the case below, the laundering of the proceeds of mass marketing fraud was achieved through the exportation of vehicles purchased with the illicit proceeds. Analysis of financial transactions identified that mass marketing fraud perpetrators based in the Asian country received funds from Canadian and American victims, which upon receipt, were returned to accomplices and entities based in Canada. The telemarketing sector is also closely associated with the "emergency" category of mass marketing fraud, and accounts for nearly 30% of the types of businesses observed.
The use of several levels of businesses allows the suspected perpetrators to dissociate themselves from the fraud.
In cases related to the "sweepstakes fraud" category, cheque cashing firms were used to bring the proceeds of fraud (in the form of numerous cheques for relatively small amounts) into the financial system.
Structuring is observed in mass marketing fraud, particularly where the activities involve cash transactions such as bank deposits or electronic funds transfers through a money service business.
Suspected perpetrators are also observed sending funds to suspected accomplices using structured electronic funds transfers through a money service business or many money service businesses. Nominees are more frequently used with "tax on lottery winnings" and "foreign money offer" categories of mass marketing fraud. These funds transfers are sent to suspected accomplices in a different jurisdiction (in this case Nigeria).
Structuring and the use of nominees are two money laundering methods which have been observed by FINTRAC.
It is therefore imperative for stakeholders to continue their collaboration to detect, deter and disrupt mass marketing fraud and the laundering of mass marketing fraud proceeds.
Additionally, this category may include, but is not limited to, offers such as extended warranties, insurance and sales services. Customs' "Operation C-Chase," led by Mazur, brought the indictment of some 100 drug lords and bankers who cleaned their dirty money -- and the collapse of the Bank of Credit and Commerce International (BCCI).
If you do not want to comment with a social network, please consider writing a letter to the editor. The "tax on lottery winnings" sub-category targets a smaller number of potential victims, but attempts to extract larger sums of money.
Here we can observe the use of trade-based money laundering techniques where, under the cover of a business, accomplices acquired used vehicles with the proceeds of fraud, which were then exported to an African country. For this category of mass marketing fraud, money service businesses were also used for currency conversion.Footnote 23Additional observations on the use of money service businesses to launder the proceeds of mass marketing fraud are covered in the "structuring" section below.
The structuring of electronic funds transfers ordered through banks is also observed, although infrequently. The use of nominees has been observed in the deposit of cash and cheques into the accounts of businesses linked to these categories, which depend largely on cash transactions. In this particular case the ultimate disposition of cash deposited in bank accounts is unknown.
While financial institutions appear to be used for suspected money laundering associated to certain mass marketing fraud schemes, many schemes appear to leverage money service businesses not only to receive funds from victims, but to launder the illicit proceeds as well.
Beyond laundering the proceeds of fraud, this strategy allows for the potential resale of the exported vehicles at a significant profit, as they will have a greater value in Africa than in Canada. The review of suspicious transaction reports and electronic funds transfer reports also identified instances where transfers were structured into multiple transactions to avoid reporting. In the suspicious transaction reports that were studied, there was also evidence of structuring of electronic funds transfers made through a money service business to foreign jurisdictions, mainly with the "sweepstakes fraud" and the "merchandise and services" categories of mass marketing fraud. The coordinated use of nominees, which consists of using a group of individuals to make multiple low-value deposits, a variation of structuring, known as "smurfing" is also observed in mass marketing fraud-related transactions. By sending structured electronic funds transfers to a different jurisdiction using suspected accomplices who are not the beneficiaries of the electronic funds transfers sent by the victims, suspected mass marketing fraud operators attempt (in this case unsuccessfully) to dissociate the funds from the fraud and seek to avoid the transaction being reported to FINTRAC through a large cash transaction or electronic funds transfer report. These reporting entities in particular should note the "red flags" included this report, and ensure that similar suspicious activity is reported to FINTRAC. Since 1905, the Gonzmart family has run the restaurant, expanding it from a bar and sandwich shop to 1,700 seats. Six nights a week, there's Flamenco dancing; anytime, there's a sangria blended tableside with hand-selected cabernet and tempranillo, a Spanish grape, and fresh fruit. You can stroll the original terrazzo tile floors, dine and drink beneath the courtroom's coffered and crown-molded ceilings, make dinner reservations at a witness stand, and sleep in a judge's chamber. The Courthouse's Infiltrator connection: It's where the trial of BCCI officers and a top cartel player took place.
The hotel's super-cool WXYZ Bar is popular for local DJ nights and hanging out amid cool art at any hour. Illegal lottery-style bolita games and Prohibition-era rum-running rocked Ybor City, distinguished by a mix of Cuban, Spanish and Sicilian culture and easy access to Tampa's port. Ybor City's 1920s bootlegging and gangland crime inspired bestselling author Dennis Lehane to write Live by Night.
Ben Affleck's film adaptation will release in 2017.The Mafia Tour, presented by Cigar City Magazine, runs about 90 minutes on select Saturdays and as private and group tours. Stops include the site of a huge mob hit, an old gambling palace, remnants of Tampa's biggest mob bar and some locations shot in The Infiltrator.Deitche covers stills to smugglers, how criminal casino operators evaded police, crime family holdings in pre-Castro Cuba and under Trafficante's leadership, and the chilling connection between the Tampa mob, CIA plots to kill Fidel Castro and the Kennedy assassination. At Cephas Hot Shop, selling aloe for health for 36 years, Cephas guided us to his colorful courtyard where The Infiltrator voodoo scene was filmed."I had the pleasure of taking Dennis Lehane on the mob tour while he was writing Live By Night to give him a feel for Ybor City and historic places where the gangsters hung out," says Deitche.



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