I’ve been back in the UK since Wednesday, what's this Brexit everyones on about!? I was in Vancouver aka Van city for over a month so am really struggling to adjust, and specifically get to sleep - I think my body-clock is broken. I am therefore restless and tired and not really fit to write. There have been sleepless nights, and when I do sleep - there are vivid dreams, nightmares even, and there is fear though there are no clowns, there are however beneficial owners from sanctioned countries. I will tell you about these dreams another time but for now let’s wrap-up the real nightmare that is the Canadian/British Columbian financial crime landscape.
So the title Silence of the Lambos is a clever pseudo-contraction of, 'Cleverly punning/using the name of a popular movie to reinforce the need for enforcing controls in relation to money laundering which would stop criminals buying Lamborghinis (amongst other luxurious things) which are also known as Lambos, (the Lambo used here and the use of Lambo (in this context) is as a symbol for luxury and to power a pun, it is in no way implied that Lambos are made for criminals or that they should be silenced in general).'
Anyway, I’m going to point out a few things that need to be addressed and give a snip of info on each. There is a fair bit to cover so will keep it brief, in line with my lethargy and quite frankly annoyance with the whole affair. It has become clear that one of my favourite places on earth, is equally attractive to criminals trying to launder money - this does hurt my feelings somewhat, as it does for the locals. While in many places Moneyland is tucked away underground with entrances hidden in fridges and wardrobes, in Van city they are regular looking doors to Moneyland, those of casinos, banks and real estate agents.
And so, on to;
Shipping
- C$43billion industry, you think cold hard cash isn’t coming in via the ships, you are wrong.
- A Peter German & Associates report on Trade Based Money Laundering would be nice.
Banks
- They obviously haven’t been doing their job when it comes to TM or KYC.
- Stop taking cash from HVDs unless they bring a reasonable KYC/AML info with them.
Underground Banking / MSBs
- Fei-Shan/Hawala
- if there are those of significant size, they should regulated to some extent.
- as this process can’t really be stopped, general improvement and lockdown in AML due diligence across the financial sector needs to be in place to stop dirty money getting into the system, even if it gets into the country.
- MSBs should be audited by regulators and;
- Banks should have reliance agreements with MSBs which are reviewed regularly to ensure compliance.
Notaries/Lawyers
- Get Lawyers reporting to FINTRAC now!
FINTRAC
- give them full on FIU superpowers, now!
Real estate
Regulator - create a regulator like in the province of Alberta, Canada - one that has the power to fine and ban.
Agents/Firms/Developers - make them accountable for KYC and AML due diligence.
Casinos
- Continue working on shoring up controls and punish current regulators freely.
- Move regulation of casinos from British Columbia Lottery Commission to neutral party.
- Transition to no-cash systems.
Luxury Cars (and other high value dealers)
Auto export - get rid of tax rebate on exports and/or introduce increased AML due diligence measures if a vehicle is noted as a future export.
Dealers - include in reporting and add laws relating to cash purchases.
Crypto
- banks should apply limits on transfers, and not allow transfers unless the exchange has solid KYC/AML programs (some do that already or don't do business with exchanges full stop).
Horse Racing
- Trainers and horse owners should be subject to AML due diligence.
- Transition to no-cash system.
- it’s not cool is it, so just stop it. Horses have feelings too, see Bojack Horseman.
Policing
BC Port Police - get some, now!
Robocop - create a robocop.
RCMP / Proposed special investigation units - Make sure it happens and has sustainable funding, resource and support where and when it counts.
Government
- Companies House but better - public
- Real Estate Register - private
- Unexplained Wealth Orders - seek and destroy.
- Make any inquiries count - remove corrupt +/ non-compliant officials
- Move regulation of casinos from British Columbia Lottery Commission to neutral party.
- make Canadian Geese less noisy.
- make Canada Goose stop using fur in their products.
“May we get what we want, may we get what we need, but may we never get what we deserve.”
That’s not too much to ask is it, though I know it is and I definitely missed some bits. I, before I die would like to celebrate a serious Canadian prosecution of money laundering, it’s now officially on my, ‘I would like to see’ list, alongside Kim Jong Uns’ diary, Putins real net worth and an app that cures hangovers. In line with that, there is an old Irish toast, “May we get what we want, may we get what we need, but may we never get what we deserve.” I imagine the Moneylanders using this and it bothers me (I'm always semi-furious), but I think we can apply it here so it’s said by the those in charge of fighting financial crime in Canada.
“May we get what we want, may we get what we need, but may we never get what we deserve.” What they want and need I have covered above to a point, what they deserve at the moment involves a visit to a CIA black site. Hmmm, maybe FinCEN or Egmont could create a black-ops division to punish other FIUs/lacklustre fincrime fighting efforts. I’ll lobby for that but until then it’s the standard political magnum opus of fingers crossed and hope for the best.
Al.
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