Financial Transactions and Reports Analysis Centre of Canada issues bulletin on detecting evasion of counter-proliferation sanctions

The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) published a Special Bulletin (FINTRAC-2025-SB001) setting out typologies and red flags to help businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act detect, prevent and report financial activity linked to the suspected evasion of counter-proliferation sanctions. The bulletin outlines how proliferation financiers and procurement networks may use trade-based money laundering techniques, complex corporate structures (including shell and front companies and nominee arrangements), correspondent banking channels, and trade finance instruments supported by falsified or misleading documentation to bypass sanctions and export controls. It highlights heightened risk where transactions involve jurisdictions of proliferation concern, including the Democratic People’s Republic of Korea, the Islamic Republic of Iran and the Russian Federation, and notes that Ministerial Directives requiring enhanced measures are in force for those jurisdictions. FINTRAC also describes indicators relevant to virtual currency activity, including exposure to exchanges and addresses associated with sanctioned jurisdictions, obfuscation techniques such as chain hopping and mixers, and links to high-risk platforms, and reiterates that reporting entities must file suspicious transaction reports where there are reasonable grounds to suspect a completed or attempted transaction relates to money laundering, terrorist financing or sanctions evasion, with sufficient detail to support financial intelligence.