I have updated my column to try to ensure that readers can get to Jessica Davis's piece. We disagree on whether FINTRAC had any regulatory capacity to receive reports on suspicious financial transactions from banking service providers regarding crowd-funding platform activity prior to the enactment of the Emergencies Act regulations . I rely here on testimony provided by the director of intelligence for FINTRAC provided in testimony to the Parliamentary special committee investigating the Emergencies Act (DEDC)--a parliamentary study that is underway in parallel with the judicial Public Order Emergency Commission. Happy to have others wade in on the arcana of FINTRAC. Following the money with regard to the Freedom Convoy might be one thread, but perhaps not the most important one, except to the extent that it might uncover aspects of foreign interference.
I see you featured my piece for The Line in your newsletter this morning - a few folks have reached out indicating that the link doesn’t work, so I thought I’d send you along a correct one (it seems to redirect to an email rather than the website): https://theline.substack.com/p/jessica-davis-im-an-intel-expert
I’ve done extensive analysis on the fundraising for the convoy that you might find interesting. Most of the money raised from the crowdfunding platforms was never distributed. Thus, the main fundraising actually came from cash and email money transfers. https://newsletter.insightthreatintel.com/p/convoy-finance-by-the-numbers. I think you’re confused about how the crowdfunding platforms work - you don’t email money through them, you use your credit card or bank card, and a payment processor completes the transaction on your behalf. The recipients themselves are still governed under the PCMLTFA, so you’re not quite right that there was no coverage either.
I have corrected my column to try to make sure that readers can get directly to Jessica's valuable guest commentary for TheLine. I think Jessica and I disagree about the authorities available to our financial intel unit, FINTRAC, prior to the passage of Emergencies Act regulations. Here I rely on the testimony provided by Barry MacKillop, the intelligence director at FINTRAC, given to the special Parliamentary committee (DEDC), which is conducting a parallel set of hearings into the invocation of the Emergencies Act. MacKillop testified that crowd source platforms were not subject to the same regulations as banking sector service providers in terms of requirements to provide FINTRAC with indications of suspicious transactions (generally over 10K) to FINTRAC, so that the agency could investigate and where appropriate provide its findings to the RCMP for law enforcement follow up. In essence, fund-raising for the so-called Freedom Convoy" was not captured by FINTRAC. The extent to which the follow the money thread is germane to an investigation into the Freedom Convoy, and the available intelligence, remains to be seen. The key question would be any knowledge of foreign interference connected to the finances of the Freedom Convoy.
No, that's not what we disagree about. It's clear from the PCMLTFA that crowdfunding sites were not regulated entities prior to the passage of the Emergencies Act. What I disagree with is your assertion that the crowdfunding campaigns amounted to funding for the convoy ("This seems to overlook the enormous amount of money generated by the crowd-sourced platforms "). The vast majority of those funds were never dispersed to intended recipients, and those that were quickly became subject to a restraint order as part of a civil process.
I have updated my column to try to ensure that readers can get to Jessica Davis's piece. We disagree on whether FINTRAC had any regulatory capacity to receive reports on suspicious financial transactions from banking service providers regarding crowd-funding platform activity prior to the enactment of the Emergencies Act regulations . I rely here on testimony provided by the director of intelligence for FINTRAC provided in testimony to the Parliamentary special committee investigating the Emergencies Act (DEDC)--a parliamentary study that is underway in parallel with the judicial Public Order Emergency Commission. Happy to have others wade in on the arcana of FINTRAC. Following the money with regard to the Freedom Convoy might be one thread, but perhaps not the most important one, except to the extent that it might uncover aspects of foreign interference.
Hi Wesley,
I see you featured my piece for The Line in your newsletter this morning - a few folks have reached out indicating that the link doesn’t work, so I thought I’d send you along a correct one (it seems to redirect to an email rather than the website): https://theline.substack.com/p/jessica-davis-im-an-intel-expert
I’ve done extensive analysis on the fundraising for the convoy that you might find interesting. Most of the money raised from the crowdfunding platforms was never distributed. Thus, the main fundraising actually came from cash and email money transfers. https://newsletter.insightthreatintel.com/p/convoy-finance-by-the-numbers. I think you’re confused about how the crowdfunding platforms work - you don’t email money through them, you use your credit card or bank card, and a payment processor completes the transaction on your behalf. The recipients themselves are still governed under the PCMLTFA, so you’re not quite right that there was no coverage either.
Have a good one,
Jessica
I have corrected my column to try to make sure that readers can get directly to Jessica's valuable guest commentary for TheLine. I think Jessica and I disagree about the authorities available to our financial intel unit, FINTRAC, prior to the passage of Emergencies Act regulations. Here I rely on the testimony provided by Barry MacKillop, the intelligence director at FINTRAC, given to the special Parliamentary committee (DEDC), which is conducting a parallel set of hearings into the invocation of the Emergencies Act. MacKillop testified that crowd source platforms were not subject to the same regulations as banking sector service providers in terms of requirements to provide FINTRAC with indications of suspicious transactions (generally over 10K) to FINTRAC, so that the agency could investigate and where appropriate provide its findings to the RCMP for law enforcement follow up. In essence, fund-raising for the so-called Freedom Convoy" was not captured by FINTRAC. The extent to which the follow the money thread is germane to an investigation into the Freedom Convoy, and the available intelligence, remains to be seen. The key question would be any knowledge of foreign interference connected to the finances of the Freedom Convoy.
No, that's not what we disagree about. It's clear from the PCMLTFA that crowdfunding sites were not regulated entities prior to the passage of the Emergencies Act. What I disagree with is your assertion that the crowdfunding campaigns amounted to funding for the convoy ("This seems to overlook the enormous amount of money generated by the crowd-sourced platforms "). The vast majority of those funds were never dispersed to intended recipients, and those that were quickly became subject to a restraint order as part of a civil process.