The Proceeds of Crime (Money Laundering) and Terrorist Financing Act has given Canada a framework, a solid basis for establishing rules on recycling money. But once the first “window of opportunity“ for recycling has closed, we find what we call second, third and fourth generation recycling. The only remaining common thread is made up of the facilitators, the lawyers, the notaries, the accountants, the tax experts who know that they are dealing with criminals who have no legitimate income, who have never been to school, but hold huge company portfolios. Those are the people who do the transactions.
