Part 2 of "The Importance of Suspicious Transaction Reporting in Criminal Investigations": retired RCMP officer Stephen Scott shares a detailed case study that demonstrates how a single suspicious transaction report (STR) filed by a financial institution was crucial in unraveling a complex money laundering and organized crime investigation. The discussion highlights the importance of frontline reporting, the challenges in connecting the dots, and the significant impact that STRs can have in taking down criminal enterprises and seizing their illicit assets.
Key Takeaways:
Stephen Scott
Company: S Scott (AML) and Security Consulting
Email: stephenscott@sscottamlsconsulting.com
Bio
Stephen Scott is a former member of the RCMP and in 2017 through 2021 was an investigations and training consultant to the UNODC GPML in Southern Africa. While in the RCMP, Stephen worked in the Calgary Integrated Proceeds of Crime AML Unit, INSET and the IMET JSIU where he managed and conducted money laundering, asset forfeiture, organized crime and terrorist financing investigations for 24 years. As a member of the RCMP IPOC AML Unit Stephen served as the FINTRAC liaison, CBSA currency interdiction contact and the “gatekeeper” to the Alberta Justice Civil Forfeiture program. He was a designer and facilitator on the RCMP Advanced and Basic Proceeds of Crime / ML courses as well as a facilitator at the Canadian Police College for the National Expert Witness training and Drafting Information to Obtain search warrants courses.
In 2019/20, Stephen Scott served on contract as a sworn member of the Royal Cayman Islands Police Service Bureau of Financial Investigations conducting international money laundering and asset forfeiture investigations.
Currently, Stephen is a licensed Private Investigator in Alberta and is currently contracted to firms that conduct due diligence, background, OSINT and asset recovery investigations.
Connect with Greg and Really Trusted at:
https://www.facebook.com/ReallyTrusted/
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Hello and welcome back to the KYC podcast.
Greg Dent:Today we're going to continue our episode
Greg Dent:with Stephen Scott, retired RCMP officer,
Greg Dent:and we're going to start with Stephen
Greg Dent:telling us a step-by-step example of a
Greg Dent:real-life case that he investigated and
Greg Dent:where the FinTrack intelligence made a
Greg Dent:difference in that case.
Stephen Scott:So let's get to it made a difference in
Stephen Scott:that case.
Stephen Scott:So let's get to it.
Stephen Scott:Had a case back several years ago where one
Stephen Scott:of our biggest bad guys code trafficker,
Stephen Scott:arms trafficker, weed trafficker here in
Stephen Scott:Calgary came to the attention of the
Stephen Scott:Alberta law enforcement response team when
Stephen Scott:he got shot in the rear end.
Stephen Scott:I was going to say I'll leave it at that.
Stephen Scott:So all of a sudden they look up this guy
Stephen Scott:and say who's this guy?
Stephen Scott:Why did he get shot?
Stephen Scott:You know, is this a gangland thing?
Stephen Scott:Is this a bystander?
Stephen Scott:Well, it turns out yeah he's a weed
Stephen Scott:trafficker, coke trafficker, deals in arms
Stephen Scott:and he's got quite a number of people
Stephen Scott:working for him.
Stephen Scott:So the alert team starts to work up an
Stephen Scott:investigation.
Stephen Scott:They call the proceeds crime team in to
Stephen Scott:work with them.
Stephen Scott:So we generally would assign one or two
Stephen Scott:members to work with the project team
Stephen Scott:that's doing this substantive case.
Stephen Scott:So as they start to build up this case, one
Stephen Scott:of the first things I did and another
Stephen Scott:member of my team was send in this
Stephen Scott:voluntary information record to FinTrack.
Stephen Scott:Does FinTrack have anything on this person?
Stephen Scott:We're investigating them for these
Stephen Scott:particular reasons.
Stephen Scott:I have reason to believe that they're
Stephen Scott:laundering money and within those first
Stephen Scott:couple of three, four weeks they have
Stephen Scott:nothing.
Stephen Scott:So there's been nothing entered by
Stephen Scott:financial institutions, casinos, msbs and
Stephen Scott:so on about the guy.
Stephen Scott:So that's fine, we go on with our
Stephen Scott:investigation.
Stephen Scott:At the same time we learn that he's just
Stephen Scott:finishing off building a property in
Stephen Scott:Bearspaw, which is a very expensive
Stephen Scott:development west of Calgary.
Stephen Scott:It turns out the house was worth about $1.5,
Stephen Scott:$1.7 million.
Stephen Scott:The house was registered and this is
Stephen Scott:important in his parents' names.
Stephen Scott:Nominees are often used in all these
Stephen Scott:properties.
Stephen Scott:And whether it's a trust, whether it's a
Stephen Scott:numbered company In commercial real estate,
Stephen Scott:that's a different ballgame again, but
Stephen Scott:personal properties.
Stephen Scott:This kid was 23 years old, he didn't hold a
Stephen Scott:job and then when we looked into the
Stephen Scott:parents because you investigate the family
Stephen Scott:in this case because everybody's part and
Stephen Scott:parcel of this dad was a cabinet builder,
Stephen Scott:cabinet maker, and mom worked in a hotel
Stephen Scott:cleaning rooms Pretty tough to own a $1.6
Stephen Scott:million property all of a sudden with those
Stephen Scott:yeah without a 1.6 million dollar property
Stephen Scott:all of a sudden, with those, yeah, without,
Stephen Scott:uh, without a mortgage.
Stephen Scott:Yeah, yeah, it must be nice and um, so
Stephen Scott:we're thinking that that's not right.
Stephen Scott:So, as the investigation goes on, we're
Stephen Scott:we're learning more about this guy.
Stephen Scott:Well, one day the surveillance team sees
Stephen Scott:him driving a lamborghini um, not unheard
Stephen Scott:of.
Stephen Scott:He had a land rover.
Stephen Scott:He had to throw the cars.
Stephen Scott:They had.
Stephen Scott:A tow business was their front business for
Stephen Scott:laundering money.
Stephen Scott:All their customers paid cash and all their
Stephen Scott:customers paid in $20 bills.
Stephen Scott:Thus he made these massive cash deposits in
Stephen Scott:the banks Under the $10,000 threshold.
Stephen Scott:No suspicious transactions came out of that
Stephen Scott:either.
Stephen Scott:That's another story.
Stephen Scott:People knock realtors, but financial
Stephen Scott:institutions, all these places still
Stephen Scott:involve people.
Stephen Scott:People have to make judgment calls.
Stephen Scott:People have to move things along based on
Stephen Scott:their knowledge, their training, their
Stephen Scott:experience.
Stephen Scott:So, anyway Lamborghini.
Stephen Scott:We might forget where this guy's purchased
Stephen Scott:this.
Stephen Scott:Well, law enforcement here in Canada,
Stephen Scott:alberta especially, has access to the
Stephen Scott:actual bill of sale documents.
Stephen Scott:So reached out to the Alberta government
Stephen Scott:special investigations unit, got a copy of
Stephen Scott:the bill of sale.
Stephen Scott:Turns out the fellow bought the car in the
Stephen Scott:states eighty eight thousand dollars give
Stephen Scott:or take there's transportation fees to
Stephen Scott:bring it back here.
Stephen Scott:I think that was close to twenty bill of
Stephen Scott:sale says on it this was paid for in full
Stephen Scott:took a chance.
Stephen Scott:We called the dealership out there,
Stephen Scott:explained who we were and what we did.
Stephen Scott:We're a little concerned that the
Stephen Scott:dealership out there explained who we were
Stephen Scott:and what we did.
Stephen Scott:We were a little concerned that the
Stephen Scott:dealership may tip off our guy One of those
Stephen Scott:judgments you make in a case like this.
Stephen Scott:We generally do investigations like that
Stephen Scott:after takedown or after the arrests so the
Stephen Scott:bad guy can't get rid of all of his assets.
Stephen Scott:So, that said, determined that you know,
Stephen Scott:maybe this fellow has sent electronic fund
Stephen Scott:transfer to the US and that will have been
Stephen Scott:captured by FinTrack, sent off my VER to
Stephen Scott:FinTrack again Within two days I did get a
Stephen Scott:disclosure back on the one transaction that
Stephen Scott:would never have come out otherwise because
Stephen Scott:it was just an EFT for $8,000 and then
Stephen Scott:transportation fees.
Stephen Scott:But what that did was identify the
Stephen Scott:financial institution where this guy sent
Stephen Scott:the EFT from One of the big five banks in
Stephen Scott:Canada.
Stephen Scott:We already knew about another bank that
Stephen Scott:hadn't given us anything.
Stephen Scott:We'd executed production orders.
Stephen Scott:We'd been through his accounts, his
Stephen Scott:business accounts.
Stephen Scott:We didn't like what we saw, but it had
Stephen Scott:nothing to do with the property.
Stephen Scott:So that one STR led to the disclosure,
Stephen Scott:which led to identifying a bank account.
Stephen Scott:So at that point we have to search the bank
Stephen Scott:accounts that are associated to that STR,
Stephen Scott:and what we do is start with a request, the
Stephen Scott:client profile, and the client profile
Stephen Scott:provides all the accounts that the person
Stephen Scott:has and all the joint accounts, and so on.
Stephen Scott:So with that client profile and learning
Stephen Scott:that he had six or seven accounts
Stephen Scott:associated to him and his family, we
Stephen Scott:searched all those accounts.
Stephen Scott:We got boxes of documents but what that did
Stephen Scott:was identify the parents' accounts, the
Stephen Scott:grandparents' accounts, his brothers'
Stephen Scott:accounts, his accounts, and each and every
Stephen Scott:one of them had a connection to building
Stephen Scott:his house.
Stephen Scott:The contractors were primarily.
Stephen Scott:We learned from there and we learned after
Stephen Scott:our arrests and searches.
Stephen Scott:At the end of the day, but building towards
Stephen Scott:that, there were checks made out to certain
Stephen Scott:you know, concrete contractors, roofing
Stephen Scott:contractors, siding contract landscapers so
Stephen Scott:that gave us all opportunities to interview
Stephen Scott:people later to determine how they were
Stephen Scott:paid.
Stephen Scott:We also learned later that you know if the
Stephen Scott:contract was $40,000, the check that was
Stephen Scott:delivered was twenty thousand and twenty
Stephen Scott:thousand dollars paid in cash, cash right.
Stephen Scott:A lot of these guys are evading taxes on
Stephen Scott:you and they like cash so you know, at the
Stephen Scott:end of the day we got this house, it was
Stephen Scott:worth a million in change.
Stephen Scott:Um, again, he had no income, the parents
Stephen Scott:had no income to be able to have paid.
Stephen Scott:Close to a million bucks was the um with
Stephen Scott:the building costs.
Stephen Scott:Uh, we, we got his business.
Stephen Scott:We got seven vehicles, we got a brightling
Stephen Scott:watch, um jewelry, cash, a couple hundred
Stephen Scott:thousand dollars in cash, and we would not
Stephen Scott:have gotten most of that without that
Stephen Scott:single str or eft, in this case, just one
Stephen Scott:small report going to fintrack right and
Stephen Scott:identifying all these other accounts.
Stephen Scott:Now had an institution determined that this
Stephen Scott:$4,500 deposit and $20 bills is not how tow
Stephen Scott:companies work, you know.
Stephen Scott:And this other $5,000 deposit, you know,
Stephen Scott:three days later.
Stephen Scott:And all these receipts they had an
Stephen Scott:accountant.
Stephen Scott:All the receipts were for cash, so hundreds
Stephen Scott:and thousands of dollars in gas payments,
Stephen Scott:expenses for the so-called business, were
Stephen Scott:all in cash.
Stephen Scott:The accountant should have done something
Stephen Scott:as well and should have submitted an STR.
Stephen Scott:Had they submitted those STRs, all that
Stephen Scott:information would have come to us quicker
Stephen Scott:because contract had to revert to begin
Stephen Scott:with.
Stephen Scott:That stays in your database.
Stephen Scott:Police are working on it.
Stephen Scott:If the STR gets sent to them boom, they're
Stephen Scott:going to send something back right away.
Stephen Scott:So that turned our whole case around.
Greg Dent:It was a single document like that yeah,
Greg Dent:it's interesting and to me it perfectly
Greg Dent:highlights this concept of the puzzle that
Greg Dent:you're trying to build on the investigation
Greg Dent:at the end that the frontline people will,
Greg Dent:unfortunately, will never know about and
Greg Dent:can't know about, to be fair.
Stephen Scott:But you never know.
Stephen Scott:But you never know how important that
Stephen Scott:little tiny thing is, very rarely is police,
Stephen Scott:do we ever get a chance to thank people for
Stephen Scott:helping out with like that.
Stephen Scott:When it comes to us in the form of a
Stephen Scott:disclosure with two dozen transactions,
Stephen Scott:five dozen transactions on a ton of
Stephen Scott:spreadsheets, you're just so overwhelmed by
Stephen Scott:the work, overwhelmed by getting something
Stephen Scott:to court, and then you're moving on to the
Stephen Scott:next one.
Stephen Scott:You don't get a chance to say, hey guys,
Stephen Scott:thank you very much.
Stephen Scott:Occasionally, back in the financial
Stephen Scott:institution world the old days I guess,
Stephen Scott:because I'm an old guy you know there's
Stephen Scott:Christmas parties or there's stampede
Stephen Scott:parties out here and you'd meet the
Stephen Scott:corporate security people.
Stephen Scott:You'd meet some of the money laundering
Stephen Scott:people.
Stephen Scott:We go to conferences, like the one coming
Stephen Scott:up in Toronto or over there, and you meet
Stephen Scott:the money laundering people there.
Stephen Scott:The real estate representative show up for
Stephen Scott:those sometimes and you meet people and
Stephen Scott:then sometimes you can share, kind of like
Stephen Scott:what I'm doing here is you know what this
Stephen Scott:actually made a difference this was a
Stephen Scott:particular case or you know it actually
Stephen Scott:results in.
Stephen Scott:You know, you talk to someone.
Stephen Scott:They say I've got something that just
Stephen Scott:doesn't seem right, steve, and they'll
Stephen Scott:explain something to me and and my response
Stephen Scott:will usually be yeah, I think that's
Stephen Scott:suspicious.
Stephen Scott:That's what we're sending in, and then we
Stephen Scott:generate more, as tr is that way, strangely
Stephen Scott:enough, or sometimes just leads.
Stephen Scott:Well, they'll send something directly to us,
Stephen Scott:but we'll also follow that up with.
Stephen Scott:You should be sending something, by the way
Stephen Scott:and then they start going through their
Stephen Scott:records, maybe, and understanding the
Stephen Scott:concept of reasonable grounds to suspect.
Greg Dent:Or you know that money laundering isn't
Greg Dent:just cash, you know, especially in real
Greg Dent:estate business, it's, it's, it's the
Greg Dent:person, it's their transaction, it's what's
Greg Dent:not normal and in what normal people, you
Greg Dent:know, versus what legitimate people do it's
Greg Dent:funny in my work, uh, as we do consults
Greg Dent:with, uh, with compliance officers as we
Greg Dent:build out new programs for them, it's
Greg Dent:fairly common, I would suggest, that we end
Greg Dent:up having a conversation around a situation
Greg Dent:that that brokerage had been involved in,
Greg Dent:that they probably should have filed a
Greg Dent:suspicious transaction report on, and I
Greg Dent:would say probably more than 50% of the
Greg Dent:consults we've had have led to us saying,
Greg Dent:hey, you might want to reconsider this,
Greg Dent:because I think there's probably reasonable
Greg Dent:grounds to suspect that this situation
Greg Dent:you've just told me about actually was a
Greg Dent:suspicious transaction.
Stephen Scott:Yeah, you know it's funny.
Stephen Scott:You know we um want to talk money
Stephen Scott:laundering as well.
Stephen Scott:Sometimes there are the people that talk,
Stephen Scott:you know, expanding on that, maybe the big
Stephen Scott:picture, money laundering, the economic
Stephen Scott:impacts, the price of houses in vancouver
Stephen Scott:and toronto and so on.
Stephen Scott:But there's also the local level and you
Stephen Scott:know the smaller towns, smaller cities.
Stephen Scott:If a drug dealer says easiest people to
Stephen Scott:pick on, you know, is putting their money
Stephen Scott:into institutions, you know they're getting
Stephen Scott:away with that so far.
Stephen Scott:But they want to buy property.
Stephen Scott:They want to buy their own investment
Stephen Scott:property or rental unit or two or three, or
Stephen Scott:their own house and so on.
Stephen Scott:You know, by submitting that STR you have
Stephen Scott:that immediate impact, even at the small
Stephen Scott:level.
Stephen Scott:You know it isn't always the big picture
Stephen Scott:stuff that I think about.
Stephen Scott:In these cases as well, it's local police
Stephen Scott:doing local work, seizing assets off of
Stephen Scott:people locally.
Stephen Scott:That shows to the local community that
Stephen Scott:crime doesn't pay.
Stephen Scott:I'm going to take your assets, I'm going to
Stephen Scott:take your car, I'm going to take your house
Stephen Scott:and if you've used that house to develop a
Stephen Scott:meth lab or a marijuana grill or something,
Stephen Scott:it's offense-related property and we're
Stephen Scott:going to seize it for that reason too.
Stephen Scott:But the person who maybe conducted a
Stephen Scott:transaction to begin with says you know
Stephen Scott:this person's a student, why are they
Stephen Scott:buying a house?
Stephen Scott:This person doesn't necessarily have
Stephen Scott:employment.
Stephen Scott:You know, we may not even have to ask them
Stephen Scott:formal questions.
Stephen Scott:You're having a conversation with the
Stephen Scott:person that you're.
Stephen Scott:You're, you know that you're acting on to
Stephen Scott:purchase a house.
Greg Dent:And if things just don't sound right, maybe
Greg Dent:they aren't right and really you as a
Greg Dent:frontline reporter don't need to go do the
Greg Dent:investigation, you just need to submit it
Greg Dent:and let FinTrack do what they will or won't,
Greg Dent:but at least you'll have done your part by
Greg Dent:flagging it, I think, is what I would say.
Greg Dent:I want to come back to something you just
Greg Dent:said, though small town thing, because I
Greg Dent:get that.
Greg Dent:I get that from a lot of people.
Greg Dent:Oh well, I'm in small town manitoba,
Greg Dent:saskatchewan, whatever.
Greg Dent:I'm in small town canada, um, money
Greg Dent:laundering doesn't happen here.
Greg Dent:Yeah, would you agree with that statement,
Greg Dent:steven?
Greg Dent:I think I know the answer.
Stephen Scott:Yeah, exactly no, no, no, because again
Stephen Scott:it's that nebulous term, if, if you will,
Stephen Scott:money laundering versus, you know,
Stephen Scott:purchasing of assets and living a certain
Stephen Scott:lifestyle that we can't aspire to ourselves
Stephen Scott:because we work and earn legitimate money.
Stephen Scott:So you know, the whole point of maybe
Stephen Scott:conducting some money laundering or many
Stephen Scott:money laundering investigations is to
Stephen Scott:identify the assets at the other end of the
Stephen Scott:person that they purchased, the investments
Stephen Scott:that they purchased, the investments again,
Stephen Scott:the lifestyle, the cars, the houses, the
Stephen Scott:real property, the rental units.
Stephen Scott:And people who make a lot of money in small
Stephen Scott:towns spend their money potentially in
Stephen Scott:small towns and if they're buying
Stephen Scott:properties in these towns and they're
Stephen Scott:buying those properties with dirty money,
Stephen Scott:well, that asset can be subject to
Stephen Scott:forfeiture.
Stephen Scott:So really, money laundering is just a
Stephen Scott:vehicle of few loads that proceeds, a crime
Stephen Scott:in motion to lead us to that asset, so we
Stephen Scott:can seek forfeiture of that asset.
Stephen Scott:Take that power.
Stephen Scott:Base away from these bad guys that if they
Stephen Scott:go to jail for that short time that they
Stephen Scott:seem to get for trafficking two or three
Stephen Scott:years we don't want them to come back and
Stephen Scott:still own that house, right.
Stephen Scott:I don't want them to sell that house in the
Stephen Scott:meantime.
Stephen Scott:Put that money in the bank or an investment
Stephen Scott:while they're in jail so when they get out
Stephen Scott:they can start up again.
Stephen Scott:You know, with with cash and with assets
Stephen Scott:behind.
Stephen Scott:So you know that's where the small town
Stephen Scott:comes into it.
Stephen Scott:I think more they wander their money to buy
Stephen Scott:assets.
Stephen Scott:But you know there's also investment
Stephen Scott:properties in smaller towns.
Stephen Scott:You know central BC through.
Stephen Scott:You know call it Vernon, call it Kelowna,
Stephen Scott:call it.
Stephen Scott:Well, it's a big place now but you know
Stephen Scott:these small towns there are cottages, there
Stephen Scott:are real estate or there are commercial
Stephen Scott:properties that are being bought up these
Stephen Scott:days.
Stephen Scott:Buy up wineries if you will.
Stephen Scott:We're just down in the new soya's area.
Stephen Scott:What's to say?
Stephen Scott:You know, so some kleptocrat or oligarch
Stephen Scott:from from overseas doesn't want to drop,
Stephen Scott:you know, 500 million dollars and buy a
Stephen Scott:winery.
Stephen Scott:That's pretty nice dirty money, yeah, yeah
Stephen Scott:yeah, so it's even more than just small
Stephen Scott:town.
Greg Dent:But those are small areas, but there's
Greg Dent:opportunity for big investments as well,
Greg Dent:yeah, well, and I think the point really is
Greg Dent:to make crime, not pay.
Stephen Scott:Yeah.
Greg Dent:And that's the objective.
Greg Dent:Lovely Well, thank you for that story.
Greg Dent:I really appreciate it.
Greg Dent:I don't want to take too much more time
Greg Dent:from our audience if so, but I did want to
Greg Dent:give you an opportunity.
Greg Dent:Was there one other like quick message that
Greg Dent:you thought was really important that you
Greg Dent:hadn't had a chance to talk about through,
Greg Dent:uh, through the course of the conversation?
Stephen Scott:um, yeah, maybe I touched on it a bit
Stephen Scott:earlier that you know too many or too often
Stephen Scott:we associate money laundering with, with
Stephen Scott:cash.
Stephen Scott:I guess, and and again with um, what the
Stephen Scott:Colin Commission talks about and what's
Stephen Scott:been in the media lately, it is that big,
Stephen Scott:nebulous, big picture problem.
Stephen Scott:As opposed to, it impacts us locally, it
Stephen Scott:impacts us domestically and so on.
Stephen Scott:So it's something that's more than that.
Stephen Scott:It is about the assets, it is about the
Stephen Scott:people, it is about the underlying crime.
Stephen Scott:But because people associate it with cash,
Stephen Scott:they're not always thinking well,
Stephen Scott:transactions are suspicious and who may be
Stephen Scott:suspicious.
Stephen Scott:Our biggest issues in law enforcement, and
Stephen Scott:even all of legal law enforcement in the
Stephen Scott:time being is knowing who the ultimate
Stephen Scott:beneficial owner of certain assets are.
Stephen Scott:If realtors can come to that or do more
Stephen Scott:investigation to determine that the
Stephen Scott:ultimate beneficial owner might be a
Stephen Scott:politically exposed person who's been
Stephen Scott:sanctioned by the Russians, might be an
Stephen Scott:oligarch, a kleptocrat, somebody who's
Stephen Scott:stolen billions from their country's oil
Stephen Scott:reserves, and so on, we need to know the
Stephen Scott:ultimate beneficial owner.
Stephen Scott:Something to keep in mind as well is the
Stephen Scott:source of funds.
Stephen Scott:Again, it doesn't have to be suspicious of
Stephen Scott:the transaction itself, but where did the
Stephen Scott:money come from?
Stephen Scott:And that's when you question the people's
Stephen Scott:employment, their status in Canada, their
Stephen Scott:associates, if you've done any adverse
Stephen Scott:media checks.
Stephen Scott:Who had disperse and did they show up?
Stephen Scott:Yeah, and a media check is having a drug
Stephen Scott:trafficking conviction or being a member of
Stephen Scott:the Hells Angels or a brother of the Hells
Stephen Scott:Angels, because nominees again coming back
Stephen Scott:to the ultimate beneficial ownership is one
Stephen Scott:of our biggest concerns, so it's Source
Stephen Scott:Funds, ubo and um, not just getting it out
Stephen Scott:of your mind that it's always about cash
Stephen Scott:and the transaction itself Now very quickly.
Stephen Scott:The attempted transaction is important,
Stephen Scott:though Someone does come to you as a
Stephen Scott:realtor and say I've got $50,000 cash I
Stephen Scott:want to put down, you're going to say no, I
Stephen Scott:know I trust enough people.
Stephen Scott:They're going to go no, no, no, go to the
Stephen Scott:bank, get a draft, go to the bank, put it
Stephen Scott:in an account, send me an e-transfer, get
Stephen Scott:it into a large trust account.
Stephen Scott:That's an attempted transaction, mind you.
Stephen Scott:That should be suspicious.
Stephen Scott:Yes, anyone that comes with that amount of
Stephen Scott:cash in my world is suspicious.
Stephen Scott:There's no excuse these days on why people
Stephen Scott:are transacting that amount of money
Stephen Scott:anymore.
Greg Dent:I rarely have $20 cash in my wallet.
Greg Dent:These days, it's all plastic.
Stephen Scott:I've laundered my own money in banks and
Stephen Scott:you're taking out money to do undercover
Stephen Scott:buys.
Stephen Scott:That don't happen and you go back to
Stephen Scott:another branch of the same bank because the
Stephen Scott:government used to deal with it.
Stephen Scott:And also you walk in with forty thousand
Stephen Scott:dollars and back in the day I had the hair
Stephen Scott:and the beard nice, yeah heller looks at
Stephen Scott:you and goes I don't think so well, I'll
Stephen Scott:take that, but let me just file this
Stephen Scott:paperwork over here.
Greg Dent:I've had paperwork filed.
Greg Dent:even though there's my ID, there's my badge,
Greg Dent:I do want to build on something you said,
Greg Dent:though, because what you just said is
Greg Dent:important for people to hear.
Greg Dent:The nature of and I guess what I want to
Greg Dent:say is the nature of being a realtor or a
Greg Dent:mortgage broker is that you're in these
Greg Dent:very personal relationships and as a result
Greg Dent:of that personal relationship, you often
Greg Dent:have information that nobody else in the
Greg Dent:world will have access to.
Greg Dent:When I go shopping with a client, if the
Greg Dent:father is the one actually there hovering
Greg Dent:over the shoulder telling their kid what
Greg Dent:they can and can't buy, that might be weird,
Greg Dent:but I'm the only one who would ever see
Greg Dent:that, because nobody else is a party to
Greg Dent:that conversation and to those flip that
Greg Dent:around, greg.
Stephen Scott:And what probably is more suspicious is, is
Stephen Scott:the kid telling the father sure you cannot
Stephen Scott:buy.
Stephen Scott:I've seen that with um vehicles.
Stephen Scott:Yeah, the vehicle is in grandma's name.
Stephen Scott:She's 67 years old, doesn't speak english,
Stephen Scott:but it's it's a ferrari, it's a corvette
Stephen Scott:yeah, so when you speak to the, the car
Stephen Scott:dealer in this case, you know it.
Stephen Scott:It's yeah, so-and-so.
Stephen Scott:Came in with his mother but he did all the
Stephen Scott:talking.
Stephen Scott:He asked about the warranties and, oddly
Stephen Scott:enough, the multimillion-dollar property
Stephen Scott:there bill of sale.
Stephen Scott:Every car was in his dad's name, right,
Stephen Scott:every truck.
Stephen Scott:But all the initials on the bill of sale.
Stephen Scott:I don't want financing His initial, want
Stephen Scott:financing his initials, his initials, yeah,
Stephen Scott:so they put that together.
Stephen Scott:So, yeah, it's um, you will see people up
Stephen Scott:close and personal and you see how they
Stephen Scott:it's, it's their behavior.
Stephen Scott:Not necessarily you know who they are,
Stephen Scott:their, their race, anything like that.
Stephen Scott:It's what they do.
Stephen Scott:That's different.
Stephen Scott:That doesn't fit with what I'm going to do
Stephen Scott:when I'm going to buy a small life and I
Stephen Scott:meet a realtor, we do this.
Stephen Scott:Hey, what do you guys do?
Stephen Scott:Hey, I'm a retired, this is what I got you
Stephen Scott:move on.
Stephen Scott:It's normal conversation.
Stephen Scott:You're much more intimate in that case and
Stephen Scott:sometimes it's harder to pass information
Stephen Scott:on.
Stephen Scott:When you're intimate with people and you're
Stephen Scott:friends with them, you humanize people and
Stephen Scott:it does make it harder to send in something
Stephen Scott:that's suspicious.
Stephen Scott:But, on the other hand, realtors and all
Stephen Scott:the other reporting entities are vulnerable
Stephen Scott:to being abused by money lenders and
Stephen Scott:criminals, people wanting to buy assets and
Stephen Scott:investments, and it's been determined the
Stephen Scott:world over for over 20 years.
Stephen Scott:So it is.
Stephen Scott:I'll say this and I'm not admonishing
Stephen Scott:anybody it is time to get with the program
Stephen Scott:now.
Stephen Scott:There's enough bad guys buying property.
Stephen Scott:We'll never stop at all.
Stephen Scott:That said, you know an STR doesn't mean you
Stephen Scott:don't make a sale.
Stephen Scott:An STR doesn't mean you don't take on a
Stephen Scott:client.
Stephen Scott:It just means I think I have reasonable
Stephen Scott:grounds to suspect it is like 25% of 100%,
Stephen Scott:beyond a reasonable doubt.
Stephen Scott:This just doesn't seem right.
Stephen Scott:I believe they're laundering money or using
Stephen Scott:this property to launder money, legitimize
Stephen Scott:their dirty money or to flip it in the
Stephen Scott:future.
Stephen Scott:That said, if you've seen a property flip
Stephen Scott:two days, flip it in the future.
Stephen Scott:That said, if you've seen a property flip
Stephen Scott:two days, you know, three days later, after
Stephen Scott:the title's gone through, if something
Stephen Scott:comes up in the land title registry that
Stephen Scott:you happen to see, or they reach you again,
Stephen Scott:reach out to sell a property again.
Stephen Scott:You know things like that are suspicious
Stephen Scott:and there's an obligation, a moral
Stephen Scott:obligation if you will, you know and this
Stephen Scott:is me moralizing as a cop to comply because
Stephen Scott:of all the violence, all the violence, all
Stephen Scott:the problems behind the scenes that we
Stephen Scott:don't see.
Greg Dent:Yeah, and from a fairly like I don't know,
Greg Dent:this is crass, but I'm going to say it
Greg Dent:anyway.
Greg Dent:As a salesperson, you can still go cash
Greg Dent:your check, You're still going to sell that
Greg Dent:property, even though you're filing a
Greg Dent:suspicious transaction report.
Greg Dent:Oh, I mean look again it's a little crass,
Greg Dent:but I think it's still true and I guess
Greg Dent:people should take some.
Stephen Scott:It's 100% true, because financial
Stephen Scott:institutions deal and that's coming back
Stephen Scott:very briefly, slightly different topic, but
Stephen Scott:included everything that they should be
Stephen Scott:doing in their compliance regime is
Stephen Scott:risk-based anyway.
Stephen Scott:So you risk assessing your clients.
Stephen Scott:Is this a high-risk person?
Stephen Scott:Well, yeah, they're from Eastern Europe.
Stephen Scott:They've just come to Canada or they've got
Stephen Scott:a third party dealing on their behalf and
Stephen Scott:we've never seen them.
Stephen Scott:They've bought a third party dealing on
Stephen Scott:their behalf and we've never seen them.
Stephen Scott:They've bought this property site unsold,
Stephen Scott:or it's a trust fund, or it's a trust and
Stephen Scott:you're not seeing the owner behind that, as
Stephen Scott:opposed to you.
Stephen Scott:Know, I'd like to think I'm no risk to buy
Stephen Scott:a place, but if all of a sudden, I turn
Stephen Scott:around next week and buy a $2.5 million
Stephen Scott:acreage outside of town here with cash, you
Stephen Scott:know, maybe my nephew, who's our realtor,
Stephen Scott:you know, might be going, hmm, yeah, maybe
Stephen Scott:he would send something in, unless I have
Stephen Scott:to say, hey, man, I won a lottery and you
Stephen Scott:know.
Stephen Scott:Even then, you know.
Greg Dent:So what I'm getting at is um, actually, I
Greg Dent:got, I got kind of sidetracked, greg,
Greg Dent:excuse me, that's okay it's funny because
Greg Dent:one of my favorite things I like to talk
Greg Dent:about is when I bought the home I'm
Greg Dent:currently talking to you from, uh, my wife
Greg Dent:and I toured it for maybe 15 minutes,
Greg Dent:probably 10 to 15 minutes.
Greg Dent:We walked outside, wrote an offer for more
Greg Dent:than full price subject free and had bought
Greg Dent:this home four hours later.
Greg Dent:Well, speed of transaction.
Greg Dent:There's a flag uh, that's a pretty big flag,
Greg Dent:in fact.
Greg Dent:Paying over over list that's a big flag,
Greg Dent:like really less so.
Greg Dent:Paying over over list that's a big flag,
Greg Dent:like really less so these days but yeah.
Greg Dent:Yeah, and and it occurred to me, as I mean
Greg Dent:I've often thought about that since that
Greg Dent:somebody probably should have filed a
Greg Dent:suspicious transaction report on me.
Greg Dent:Not that I was laundering money, I was
Greg Dent:responding to the market conditions.
Greg Dent:I had perfectly good reason to do what I do
Greg Dent:is doing was doing.
Stephen Scott:But there's some big str flies, yeah, but
Stephen Scott:that goes into the risk assessment.
Stephen Scott:Um, my wife and I were looking at a condo,
Stephen Scott:potentially on behalf of her daughter, and
Stephen Scott:you know, hey, we're gonna ask market price
Stephen Scott:and slightly more if necessary.
Stephen Scott:Apparently there's 10 offers before we even
Stephen Scott:made a call.
Stephen Scott:You know so.
Stephen Scott:But it would have been done.
Stephen Scott:Hey, I can close it.
Stephen Scott:This was like a sunday called, called my
Stephen Scott:nephew and said this is what we want to do.
Stephen Scott:He calls back on Monday and says this is
Stephen Scott:the case and I said look, tell them I'll
Stephen Scott:close on Wednesday.
Stephen Scott:Yeah, I can pay full price for this right
Stephen Scott:now, just pull out some savings and so on.
Stephen Scott:So, yeah, again part of the risk assessment.
Stephen Scott:That's where I got sidetracked earlier, if
Stephen Scott:you will.
Greg Dent:No way.
Stephen Scott:You're assessing everybody you deal with
Stephen Scott:and you're documenting that risk assessment
Stephen Scott:and you're documenting that risk assessment.
Stephen Scott:It shouldn't be a tick box type of thing,
Stephen Scott:but you can make it easy and make it that
Stephen Scott:way though.
Stephen Scott:You know where are they from, you know
Stephen Scott:what's their source of funds the questions
Stephen Scott:that we put together earlier and if there
Stephen Scott:are actual indicators or terminology that
Stephen Scott:people can use.
Stephen Scott:You know this money came from a
Stephen Scott:jurisdiction of concern or we don't know
Stephen Scott:the person's source of funds.
Stephen Scott:That's the type of information a slightly
Stephen Scott:different topic that goes into the SDR, but
Stephen Scott:it becomes really helpful.
Stephen Scott:It will generate interest by that FinTrack
Stephen Scott:analyst when people use that terminology
Stephen Scott:properly too.
Greg Dent:Yeah, no, this is great.
Greg Dent:Thank you so much.
Greg Dent:I really appreciate hearing from the other
Greg Dent:side of the front lines, because it really
Greg Dent:does address something that a lot of our
Greg Dent:clients often ask about, which is, I feel
Greg Dent:like I'm just shouting into the wind with
Greg Dent:this stuff, and to hear you talk through
Greg Dent:how important the data that is coming
Greg Dent:through Fintrack can be to actually solving
Greg Dent:real-world bad crime is, I hope, helpful
Greg Dent:and, to me, is encouraging, and I think
Greg Dent:people will generally get some value out of
Greg Dent:that.
Greg Dent:So thank you for being able to do it.
Stephen Scott:And, if I may finish, every single case,
Stephen Scott:like I say, will include a FinTrack
Stephen Scott:disclosure.
Stephen Scott:These days, every major project, every bad
Stephen Scott:guy, every fraud, every whatever, and
Stephen Scott:buried within that are STRs from other
Stephen Scott:reporting entities that give us leads that
Stephen Scott:take us further, because really, the only
Stephen Scott:way to go after these guys is to seize
Stephen Scott:their assets and take that power away from
Stephen Scott:them.
Stephen Scott:Crime shouldn't pay.
Stephen Scott:And these STRs from realtors and I'd love
Stephen Scott:to see more of them because I know they
Stephen Scott:will provide some great, great information
Stephen Scott:and stuff that's collected will lead to so
Stephen Scott:much more.
Stephen Scott:And if, at a certain point, the police
Stephen Scott:decide to execute a production order on a
Stephen Scott:real estate office and I don't want to
Stephen Scott:scare anybody by saying that you know what
Stephen Scott:may be in that file may provide other leads
Stephen Scott:as well, other financial accounts and so on.
Stephen Scott:Because, again, it doesn't necessarily
Stephen Scott:include bank accounts in these STRs if
Stephen Scott:they're not known, if there's an attempted
Stephen Scott:transaction, but you know, at some point in
Stephen Scott:the future that evidence or that
Stephen Scott:information is going to become evidence and
Stephen Scott:it's going to be useful.
Stephen Scott:Because, again, yeah, these pieces of a
Stephen Scott:puzzle count and I'll stand by that after
Stephen Scott:30 years of doing this.
Greg Dent:No, and I think I will give you.
Greg Dent:I will end this, I think, with a bit of a
Greg Dent:positive note and a positive spin which is
Greg Dent:in our work.
Greg Dent:We're seeing already that the culture of
Greg Dent:compliance that has been missing.
Greg Dent:People are starting to get that message and
Greg Dent:they're starting to see where they should
Greg Dent:be filing STRs.
Greg Dent:In our work we have a bunch of brokerages I
Greg Dent:don't even it's double digits who are
Greg Dent:waiting to file STRs.
Greg Dent:Waiting because the web reporting thing
Greg Dent:isn't back up yet.
Greg Dent:Actually it is.
Greg Dent:They have a phase two trial out of the new
Greg Dent:web reporting I heard this last week, so
Greg Dent:it's almost back up but phase two trial out
Greg Dent:of the new rubber horn and I heard this
Greg Dent:last week, so it's almost back up.
Greg Dent:But anyhow, my point is waiting to file
Greg Dent:pretty soon.
Greg Dent:Um, that, uh, that, that.
Greg Dent:But that wouldn't have been true 10 years
Greg Dent:ago because it just there was not that
Greg Dent:culture of compliance, there was not that
Greg Dent:awareness of what should be happening yeah,
Greg Dent:no, I can guarantee there's no better
Greg Dent:feeling.
Stephen Scott:You can get a fendrick disclosure that's
Stephen Scott:got good information or good intelligence
Stephen Scott:in it that we can use for something else.
Stephen Scott:It's like, well, I got that guy now, or I
Stephen Scott:got this, or I've got something new.
Stephen Scott:People like I'll say, people like me, the
Stephen Scott:dozens and dozens of money laundering,
Stephen Scott:asset forfeiture people thrive on that.
Stephen Scott:You know that's what makes our cases and
Stephen Scott:when we present some of our proceeds of
Stephen Scott:crime cases, money laundering cases, to
Stephen Scott:these substantive teams, the drug teams,
Stephen Scott:human trafficking teams and you show these
Stephen Scott:people I've seized this house, I've seized
Stephen Scott:this car, I've seized a donut shop years
Stephen Scott:ago.
Stephen Scott:That's another story.
Greg Dent:That's a dangerous one for a police officer,
Greg Dent:but anyhow.
Stephen Scott:I'll leave that part alone.
Stephen Scott:Yeah, we had a city police car pull up
Stephen Scott:while we were executing the paperwork.
Stephen Scott:A fellow looks at me and says so.
Stephen Scott:I said hey, by the way, we just put a
Stephen Scott:restraint against this property.
Stephen Scott:He says what does that mean?
Stephen Scott:I said well, the government kind of owns
Stephen Scott:this now until we can sort out the fact
Stephen Scott:that these people are drug traffickers and
Stephen Scott:they get convicted and it gets forfeited.
Stephen Scott:He looks at me and says so Steve, does that
Stephen Scott:mean I get free donuts?
Stephen Scott:He said not likely.
Stephen Scott:Now, man, I'm the owner of this place.
Stephen Scott:I'm going to pay as much money as I can.
Stephen Scott:But no, I appreciate if everyone starts to
Stephen Scott:do this, it keeps it going.
Stephen Scott:As I say, it's.
Stephen Scott:Hopefully some of my excitements come out
Stephen Scott:here that I believe strongly in this and I
Stephen Scott:still do it, and I know again the dozens
Stephen Scott:and dozens of people that work these
Stephen Scott:investigations just thrive on this, and it
Stephen Scott:is really one of the most important ways to
Stephen Scott:take down bad guys is to take their stuff
Stephen Scott:and put them in jail.
Stephen Scott:But it goes part and parcel.
Stephen Scott:As far as I've seen, and it's proven around
Stephen Scott:the world yeah, absolutely.
Greg Dent:Well, thank you so much, Stephen, much
Greg Dent:appreciated.
Stephen Scott:Thank you for having me Talk again.