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The money leaves no footprints, but the question is whether anyone follows

FATF review finds Canada improved its anti-money laundering framework but still struggles to prosecute complex cases, with only 10% of laundering charges resulting in convictions.

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Naomi

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The money leaves no footprints, but the question is whether anyone follows

Money, unlike most things, leaves no footprints unless someone is trained to look for them. In Canada, a country that moves billions through its banks and real estate markets each day, the question of whether those footprints are being followed has lingered for years—a quiet unease about whether the machinery of justice can keep pace with the sophistication of those who would abuse it. A new international review suggests the answer is: better than before, but not yet good enough.

The Financial Action Task Force, the global watchdog that evaluates countries’ defenses against money laundering and terrorist financing, released its long-awaited mutual evaluation of Canada this week. The report, conducted over fourteen months with a three-week on-site visit in November 2025, interviewed more than 700 representatives from government, law enforcement, financial institutions, and civil society . Its central finding is one of qualified progress: Canada has strengthened its framework, but still struggles to prosecute the most complex cases.

The numbers tell a story that words alone cannot. Between fiscal 2019-20 and 2023-24, Canadian prosecutors handled 703 cases involving a charge of laundering the proceeds of crime. Nearly half resulted in a finding of guilt—but only 10 percent of the actual money laundering charges led to a guilty decision. In 86 percent of cases, the laundering charge was withdrawn, dismissed, discharged, or stayed, often in favor of securing convictions on predicate offenses like drug trafficking or fraud that carry heavier penalties .

The FATF described what it called “persistent challenges” in prosecuting professional money laundering, particularly in standalone cases where the underlying crime cannot be prosecuted. Such cases, the assessors noted, are “high value and sophisticated, but difficult to prove” . Money laundering in Canada is linked mainly to drug trafficking, fraud, commercial trade fraud, and tax crimes—often involving organized crime groups and professional intermediaries who insulate themselves from the dirty money they move .

The report also flagged gaps in oversight of sectors particularly vulnerable to abuse. Real estate brokers, dealers in precious metals and stones, and lawyers remain areas of concern. While law societies have taken steps to reinforce anti-money laundering obligations, the FATF found “uneven coverage, sectoral gaps and limited supervisory intensity” . Provinces also vary in how they implement beneficial ownership registries and pursue civil forfeiture, creating an inconsistent patchwork across the country .

There are genuine strengths, however. The FATF praised FINTRAC, Canada’s financial intelligence unit, for “strong capability in terms of strategic intelligence, research and analytics” . It noted that Canada has “a mature and nuanced understanding of its illicit finance risks” and has taken significant steps to strengthen corporate transparency since its last evaluation in 2016 . The country was moved from “enhanced follow-up” to “regular follow-up,” a meaningful improvement that means the FATF sees fewer systemic deficiencies requiring intense scrutiny.

Finance Minister François-Philippe Champagne welcomed the report as validation of the government’s efforts and pointed to the planned Financial Crimes Agency, a specialized federal law enforcement body that would investigate money-related offenses and contribute to asset recovery . The FATF recommended that Canada develop a comprehensive strategy to help that agency address sophisticated financial crimes—a reminder that institutional architecture alone is not enough without the resources and expertise to make it function.

For Canadians, the stakes extend beyond abstract notions of financial integrity. Government data suggests between C$45 billion and C$113 billion is laundered in Canada annually . That is money that could have funded healthcare, education, or infrastructure—or that could be fueling the very criminal networks that bring violence to communities. The FATF’s verdict is neither a failing grade nor a clean bill of health. It is an acknowledgment that the work of following money’s invisible trail is slow, painstaking, and never quite finished.

Image disclaimer: The visuals accompanying this article are AI-generated and do not depict actual events or individuals.

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Sources: The Globe and Mail, Reuters, The Canadian Press, AML Intelligence

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