Episode 11

Human Trafficking in Canada: A Compliance Perspective (Part 2)

Human trafficking happens in plain sight and is often sustained by organized networks operating within seemingly legitimate businesses. In this episode, Jinisha Bhatt, an anti-financial crime consultant and investigator, sheds light on the chilling realities of human trafficking in Canada. She outlines how criminal networks exploit systemic vulnerabilities to traffic individuals, launder funds, and evade detection, focusing on illicit massage businesses as a case study. Bhatt emphasizes the responsibility of professionals in real estate, finance, and property management to recognize red flags and take incremental steps to disrupt these criminal enterprises. Bhatt highlights the profound human cost of trafficking and the critical need for a coordinated, multidisciplinary approach involving law enforcement, property managers, licensing authorities, and financial crime professionals. She also discusses how collaboration and awareness can help dismantle trafficking networks, empower victims, and reduce exploitation. This episode not only informs but inspires action, demonstrating how small changes in vigilance and reporting can contribute to meaningful progress against human trafficking.

Key Takeaways

  • Traffickers rely on complex, multi-role networks, including recruiters, "mamasans," money handlers, and legal professionals to sustain their operations.
  • Red flags in illicit businesses include generic branding, restricted access, cash-heavy transactions, and excessive surveillance.
  • Trafficking networks exploit loopholes in licensing, immigration, and financial systems to operate with minimal risk.
  • Incremental actions like raising awareness, identifying suspicious patterns, and improving reporting accuracy can make a difference.
  • Effective intervention requires multidisciplinary collaboration among law enforcement, financial professionals, and community stakeholders.

Resources Mentioned

  • FINTRAC's special bulletin on lawyers' involvement in money laundering was referenced.

Guest bio:

Jinisha Bhatt is the Founder of CAHTC (Canada Anti-Human Trafficking Consortium) and an anti-financial crime investigator operating at the critical intersection of Anti-Money Laundering (AML) and Human Trafficking (HT). She specializes in multi-jurisdictional crypto fraud and money laundering investigations, focusing on the profound human cost of financial crime. Drawn to the field by a strong belief that most crimes against humanity, society, and the environment are financially motivated, Jinisha sees her work as a way to make a meaningful impact on these issues.

Learn more about CAHTC at www.fighthumantrafficking.ca or connect with Jinisha on LinkedIn at www.jinisha.ca

Connect with Greg and ReallyTrusted at:

https://reallytrusted.com/

https://www.facebook.com/ReallyTrusted/


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Transcript
Troy Lacher:

Welcome back to part two of our conversation on

Troy Lacher:

human trafficking and anti money laundering in Canada. If you

Troy Lacher:

tuned into the first half, you heard our guest anti financial

Troy Lacher:

crime consultant and human trafficking investigator

Troy Lacher:

jenishabat, outline the grim realities of human trafficking

Troy Lacher:

across the country and the impact it has on vulnerable

Troy Lacher:

individuals. We explored the types of exploitation that exist

Troy Lacher:

right under our noses, and began discussing how organized crime

Troy Lacher:

networks sustain this industry. In this episode, we'll dive

Troy Lacher:

deeper into the inner workings of trafficking networks, how

Troy Lacher:

they operate, launder funds and evade detection. Janesha also

Troy Lacher:

shares specific red flags and practical advice for

Troy Lacher:

professionals in real estate finance and beyond, so you can

Troy Lacher:

recognize potential trafficking cases and be part of the

Troy Lacher:

solution. Let's get back to our conversation and explore the

Troy Lacher:

tools we can all use to make a difference in the fight against

Troy Lacher:

human trafficking.

Jinisha Bhatt:

So typically, you'll see someone who has all

Jinisha Bhatt:

this money, has to wash it somehow, and is using quite a

Jinisha Bhatt:

few nominees or brokers, or whatever you want to call them

Jinisha Bhatt:

to, to straw man, their their buying. Does that answer your

Jinisha Bhatt:

question? Yeah,

Greg Dent:

certainly. And I mean, I think how that would try

Greg Dent:

to kind of really make that real for for a real estate agent or

Greg Dent:

mortgage broker, it's the person who walks in and explains they

Greg Dent:

have to do this deal, but really has no understanding of the

Greg Dent:

background behind the deal that they're presenting as something

Greg Dent:

they absolutely need to do. And you know that could be the the

Greg Dent:

investor client who wants to buy a proper a rental property, but

Greg Dent:

who, like never talks with you about any rental rates or

Greg Dent:

vacancy or property management services or anything like that,

Greg Dent:

like, Well, that seems weird, because suddenly the that that

Greg Dent:

there's a disc disconnection there that should be sparking

Greg Dent:

some further conversation, and to think that that might lead to

Greg Dent:

Human trafficking is actually like a really interesting way to

Greg Dent:

get there. So, yeah, I

Jinisha Bhatt:

think a great way of thinking about this is just

Jinisha Bhatt:

like a criminal enterprise. I think they might have their

Jinisha Bhatt:

tentacles in very many market segments or verticals. I mean,

Jinisha Bhatt:

if you think like a criminal, you would too, right? So it's

Jinisha Bhatt:

not just someone who's human trafficking. Now, if they live

Jinisha Bhatt:

on the West Coast, they could be dealing with gangs or like

Jinisha Bhatt:

supporting money laundering structuring, happening through

Jinisha Bhatt:

casinos, etc. They could also be supporting Mexican drug cartels

Jinisha Bhatt:

with washing their drug proceeds, which apparently is an

Jinisha Bhatt:

organized service that you know, Chinese criminals do offer so I

Jinisha Bhatt:

do extensive investigations on illicit massage businesses, and

Jinisha Bhatt:

that's where I kind of modeled off this one to $2 million of

Jinisha Bhatt:

victim figure. It's very typical. It's a very average

Jinisha Bhatt:

number for them. Wow,

Greg Dent:

you brought up illicit massage businesses, so,

Greg Dent:

and you've talked about the that that's an important part of the

Greg Dent:

the repertoire of a of a human trafficker. Can you kind of

Greg Dent:

explain that to go, go into the the details of how that plays

Greg Dent:

out, and why that's important as a tool of money laundering, in

Greg Dent:

that in this business, in this illegal business,

Jinisha Bhatt:

illicit massage businesses. Yeah, yeah. Okay. So

Jinisha Bhatt:

it started in early 2000s maybe late 90s in the United States,

Jinisha Bhatt:

first when Chinese organized criminals realized that they can

Jinisha Bhatt:

bring women to be trafficked here, and they can take

Jinisha Bhatt:

advantage of our asylum. You know, mechanism, sorry, asylum

Jinisha Bhatt:

visas, or what do you call them? Asylum shelters?

Greg Dent:

Oh, okay, like a refugee status. Person, asylum

Jinisha Bhatt:

status, yes, yes, yes, yes. So they they found

Jinisha Bhatt:

this vulnerability they could take advantage of. The other

Jinisha Bhatt:

thing they found is an opportunity, because it appears

Jinisha Bhatt:

that many buyers have a have an interest in Asian women. And,

Jinisha Bhatt:

you know, they, they've they fetishize Asian women. And so

Jinisha Bhatt:

the criminals knew exactly how to speak to these buyers, and at

Jinisha Bhatt:

that time, none of these services existed. So what they

Jinisha Bhatt:

did is created a very legitimate looking enterprise, and that's

Jinisha Bhatt:

why we say everything happens in plain sight, because this is

Jinisha Bhatt:

trafficking behind the veils of a legitimate massage business.

Jinisha Bhatt:

They can be licensed, and then they can be even issuing RMT

Jinisha Bhatt:

receipts, which does happen here in Canada especially, but the

Jinisha Bhatt:

receipts are coming from a legitimate person. What happens

Jinisha Bhatt:

behind closed doors is full services being. Offered. Now the

Jinisha Bhatt:

way the recruitment happens is something we need to understand.

Jinisha Bhatt:

These women are systematically brought here. They're sold this

Jinisha Bhatt:

dream of, you know, living in the West, in Canada. As of late,

Jinisha Bhatt:

they've been coming as international students. Before

Jinisha Bhatt:

they might have come as like religiously persecuted refugees

Jinisha Bhatt:

or visitors, even. And now they have incurred this huge debt,

Jinisha Bhatt:

typically, 30,000 US dollars, that's the average debt. And now

Jinisha Bhatt:

they've come here thinking they're going to be able to

Jinisha Bhatt:

repay the debt,

Greg Dent:

okay? And they they do the work in these massage

Greg Dent:

businesses to repay this debt, and presumably it's a never

Greg Dent:

ending debt cycle that they enter into as as part of the

Greg Dent:

services of working in the massage business. I suppose is

Greg Dent:

how this plays out, is that the reality of life for for some of

Greg Dent:

these victims, yeah,

Jinisha Bhatt:

it's much worse. It's really unfathomable how

Jinisha Bhatt:

painful their lives are. Once they get here, they already come

Jinisha Bhatt:

from a culture where they might not be accepted socially if

Jinisha Bhatt:

they're older, say in mid 20s. You know they usually call them

Jinisha Bhatt:

like throw away women, women who are not accepted by a family, by

Jinisha Bhatt:

a husband. Now what are you going to do with them so they're

Jinisha Bhatt:

socially ostracized. They come here. They have this youth that,

Jinisha Bhatt:

and now this IMB family becomes their new family. So now they

Jinisha Bhatt:

are grooming them to say, These Canadian men, these American men

Jinisha Bhatt:

are God, you do whatever it takes to please them, and you do

Jinisha Bhatt:

not complain, because now we have your documents, and now

Jinisha Bhatt:

they will take you away. You're you know you're not here

Jinisha Bhatt:

legally. So now they know that they cannot trust law

Jinisha Bhatt:

enforcement. They also really don't speak the language that

Jinisha Bhatt:

well. There is so many other cultural factors that we don't

Jinisha Bhatt:

appreciate, all the nuances we don't appreciate as a western

Jinisha Bhatt:

society, but this is a collective culture. They feel

Jinisha Bhatt:

shame and stigma. They are constantly afraid that their

Jinisha Bhatt:

photos are going to be placed on WeChat, where the whole

Jinisha Bhatt:

community is watching them. So now they're in debt. They

Jinisha Bhatt:

realize that that only keeps getting bigger and bigger,

Jinisha Bhatt:

because now they're charged for every towel they'll use, every

Jinisha Bhatt:

meal they will make in the back of that massage parlor, in a

Jinisha Bhatt:

rice cooker, every piece of condom, or every little bit of

Jinisha Bhatt:

loop they will use, they will just continue to inflate and

Jinisha Bhatt:

they are never getting out. Essentially, wow,

Greg Dent:

truly, wow. I can I'm kind of speechless at the at the

Greg Dent:

at all of that. So sorry, go ahead. I have

Jinisha Bhatt:

to say, because there might be some people who

Jinisha Bhatt:

go to legitimate massage places ran by Canadian, Chinese

Jinisha Bhatt:

nationals, and that's acceptable. You know, we have to

Jinisha Bhatt:

understand there are indicators that will tell you what

Jinisha Bhatt:

vulnerability. Vulnerability looks like, not every Asian

Jinisha Bhatt:

owned massage business. We're not claiming that that's a

Jinisha Bhatt:

trafficking entity,

Greg Dent:

yeah, and that's that's exactly where my mind

Greg Dent:

went to next, which is okay, so this is clearly horrible, and as

Greg Dent:

a society, I think we could all get behind this, not being

Greg Dent:

something that exists and or is allowed to operate in Canada, as

Greg Dent:

a realtor, as a property manager, as a mortgage broker,

Greg Dent:

what might I see? What might that look like? How would I even

Greg Dent:

know and where might that interact with my with my

Greg Dent:

business? I suppose

Jinisha Bhatt:

I think as a property manager more so. And so

Jinisha Bhatt:

what I teach law enforcement, how to interdict and how to

Jinisha Bhatt:

investigate these establishments. And the first

Jinisha Bhatt:

thing we teach is work with landlords and property managers,

Jinisha Bhatt:

because if your property manager knew that in their property

Jinisha Bhatt:

there is nefarious activity happening, and if somebody like

Jinisha Bhatt:

the ministry of labor or even someone like the Realtors

Jinisha Bhatt:

Association sent them a letter saying, Do you know this is

Jinisha Bhatt:

happening? Are you okay with this? You know we are not okay

Jinisha Bhatt:

with this, and we are going to report this. Then they might

Jinisha Bhatt:

take it more seriously. Now, if you're showing property, I don't

Jinisha Bhatt:

know if you ever have a chance to to visit, you will see signs

Jinisha Bhatt:

that are very clear of nefarious activity. For one, you know, if

Jinisha Bhatt:

you have this nice massage business. You're advertising

Jinisha Bhatt:

your massage skills, right? So you're not trying to hide

Jinisha Bhatt:

yourself. You're behind curtains. You're there is no

Jinisha Bhatt:

drapery like you want people to know you're offering amazing

Jinisha Bhatt:

massage services inside. So that would be the first thing.

Jinisha Bhatt:

Secondly, you won't have, like, 16 surveillance cameras in the

Jinisha Bhatt:

front and like some in the back. And then you won't have a rare

Jinisha Bhatt:

entrance for some special customers to come. You won't

Jinisha Bhatt:

have this, like, cars creeping behind the plaza and then

Jinisha Bhatt:

parking behind the IMB to go in, and then as soon as you walk in,

Jinisha Bhatt:

you'll see. You multiple cameras, you'll see an ATM

Jinisha Bhatt:

because, you know, they prefer cash and white label ATMs. So

Jinisha Bhatt:

you'll definitely see that you cannot, typically just walk in.

Jinisha Bhatt:

You have to ring the bell or and as a woman, and I've done a lot

Jinisha Bhatt:

of these field investigations, even even in Canada, as a woman,

Jinisha Bhatt:

I'd never get a chance to walk in, but as I just wouldn't be

Jinisha Bhatt:

allowed in, yeah, like, because there is a vestibule, and then

Jinisha Bhatt:

there is usually the main door, so you'll be waiting in a

Jinisha Bhatt:

vestibule. And I have, and I've had five to 10 minute long

Jinisha Bhatt:

conversations with women who would talk to me, but they would

Jinisha Bhatt:

not let me in. They would not let me book an appointment. But

Jinisha Bhatt:

for you, for a man, they might let you book an appointment.

Jinisha Bhatt:

Typically, they will take your number. They'll text you so that

Jinisha Bhatt:

now they know who you are, and now you're a trusted contact.

Jinisha Bhatt:

And so the next time you go, all you have to do is text and book

Jinisha Bhatt:

an appointment. And that's not how a typical business operates.

Jinisha Bhatt:

Now, if you get to go in, you'll see a lot more. You'll see a

Jinisha Bhatt:

makeshift kitchen with very little like, if you go to the

Jinisha Bhatt:

very end, like there are living quarters for many of these

Jinisha Bhatt:

establishments, and if they're not, then the victims are likely

Jinisha Bhatt:

living very close to the establishment, like in an

Jinisha Bhatt:

apartment altogether with the mama San, who is essentially a

Jinisha Bhatt:

lady who is a manager who was a former victim, and, yeah, you'll

Jinisha Bhatt:

see all those kind of signs. You'll see that the women who

Jinisha Bhatt:

are working there are typically not having long conversations

Jinisha Bhatt:

with you, and you will have to pay to the older woman at

Jinisha Bhatt:

reception. And then once you go in, is when you can have an

Jinisha Bhatt:

negotiation of services and pay that tip to get the services you

Jinisha Bhatt:

want.

Greg Dent:

Fascinating. It occurs to me that as a landlord,

Greg Dent:

as a property manager, there's almost like a look that a

Greg Dent:

facility like this might have that would be different than a

Greg Dent:

typical massage business, and as a property manager or as a

Greg Dent:

landlord, it's not unusual to come and do a walk through of

Greg Dent:

your home, or of your home, sorry, of your business, of the

Greg Dent:

property you are renting. And so it wouldn't be all that

Greg Dent:

difficult, just based on what you've talked about, to be able

Greg Dent:

to say, Okay, this is a legitimate response business,

Greg Dent:

which totally fine. And this is completely not a legitimate

Greg Dent:

massage business. They just, they look from from your

Greg Dent:

description, they look and feel different. I've been to massage

Greg Dent:

businesses. They were legitimate. I feel very

Greg Dent:

confident about that, and what you've described is not my

Greg Dent:

experience. So

Jinisha Bhatt:

yeah, and I think the first thing is, you know,

Jinisha Bhatt:

they're very proud of their branding, right? Legitimate

Jinisha Bhatt:

businesses, because they want to stand out like we are. This is

Jinisha Bhatt:

our name. A lot of the many imbs I've seen, they may have a very

Jinisha Bhatt:

generic sign, like a lot of the signs of the same, because these

Jinisha Bhatt:

are cookie cutter signs, you know, made by someone who makes

Jinisha Bhatt:

all these signs. And also they know that they might, they could

Jinisha Bhatt:

lose their license. And in Canada, it's not been happening,

Jinisha Bhatt:

right? But in a tougher jurisdiction, they know they

Jinisha Bhatt:

could lose their license, so they might have to move any day.

Jinisha Bhatt:

Why invest in branding? Why bother sorry.

Greg Dent:

Can I double click on that for a second? Did you just

Greg Dent:

say it's easier in Canada as a massage business, as in, sorry,

Greg Dent:

as an illegal massage business to operate?

Jinisha Bhatt:

I believe so. Wow, it's not easier. I mean,

Jinisha Bhatt:

it's also easier in the states to open one, but at least there

Jinisha Bhatt:

is some prosecution action happening. And because they have

Jinisha Bhatt:

such a serious problem, they definitely have many, many more

Jinisha Bhatt:

I m B's than we do here. There are jurisdictions that are

Jinisha Bhatt:

taking this very seriously. They're working with the

Jinisha Bhatt:

licensing departments here. We don't really have a national

Jinisha Bhatt:

strategy on this, and as lofty as it sounds, that's what I'm

Jinisha Bhatt:

actually trying to change. I'm trying to work with law

Jinisha Bhatt:

enforcement and tell them about all these signs and how to do a

Jinisha Bhatt:

multi disciplinary investigation. Because if you

Jinisha Bhatt:

really think about the number of women caught in these imvs, I

Jinisha Bhatt:

would say at least 15 to 20,000 in our country. And I don't want

Jinisha Bhatt:

to live in a country like that where we have all these modern

Jinisha Bhatt:

day slaves,

Greg Dent:

yeah, particularly when it seems like there's just

Greg Dent:

not easy, because nothing's easy, I suppose, but when

Greg Dent:

there's a whole bunch of things that could easily happen

Greg Dent:

together, I would imagine if somebody were to go ask the

Greg Dent:

mortgage, sorry, the massage. What's the licensing body for

Greg Dent:

massage professionals? The name of which escapes me, because,

Greg Dent:

because I don't know, but they probably would be very much on

Greg Dent:

board with helping in some sort of a licensing scheme to to help

Greg Dent:

eliminate this or to make it harder to operate as such, I

Greg Dent:

would think, anyhow, yeah,

Jinisha Bhatt:

I think they do their work inside. And that's

Jinisha Bhatt:

not to blame either entity, but that's the real issue. Losing a

Jinisha Bhatt:

license doesn't really deter this kind of crime. They could

Jinisha Bhatt:

move to another city, another jurisdiction. We have to do

Jinisha Bhatt:

multi disciplinary action. We have to do it simultaneously,

Jinisha Bhatt:

where you not only lose your license, you have violated labor

Jinisha Bhatt:

laws, and so the Ministry of Labor is aware of that, and you

Jinisha Bhatt:

you have all these injunctions, and then the law enforcement

Jinisha Bhatt:

investigators show up to do their criminal investigations,

Jinisha Bhatt:

which is really not happening at the moment, because we don't

Jinisha Bhatt:

really know who has jurisdiction, other than

Jinisha Bhatt:

Ministry of Labor, and we don't really believe, from my

Jinisha Bhatt:

conversations with law enforcement, we don't believe

Jinisha Bhatt:

that we can actually get evidence without victim

Jinisha Bhatt:

testimony, but our whole strategy against human

Jinisha Bhatt:

trafficking has been trying to inform this, that we should be

Jinisha Bhatt:

able to work with our victim testimony, right? Yeah, and

Jinisha Bhatt:

that's where financial crime professionals come in. There is

Jinisha Bhatt:

a Nexus. You asked me about this network. I am bees are very

Jinisha Bhatt:

networked. So we could talk about that in a bit, if you

Jinisha Bhatt:

like. Sure, let's

Greg Dent:

go. Let's get into that. That sounds. That sounds

Greg Dent:

like a natural next place for us here. Yeah. So what does that?

Greg Dent:

What does that look like? And what do I need to know about

Greg Dent:

that? I suppose,

Jinisha Bhatt:

just like law enforcement and, you know,

Jinisha Bhatt:

public sector entities, I think there is a great room for

Jinisha Bhatt:

collaboration in our industry. So what an IMB network looks

Jinisha Bhatt:

like? And every kind of trafficking entity will have a

Jinisha Bhatt:

network. But let's talk about IMDs. They have one person

Jinisha Bhatt:

responsible, okay, for before firstly, let's say one owner, so

Jinisha Bhatt:

one big mansion owner in Vancouver on Vancouver Island,

Jinisha Bhatt:

for example, owns five or six or seven imbs across the province.

Jinisha Bhatt:

Okay. Now they are rarely visible anywhere on paper or at

Jinisha Bhatt:

the premises, and that's why law enforcement investigations are

Jinisha Bhatt:

difficult. What they have instead are a network of

Jinisha Bhatt:

individuals acting as nominees and brokers. So the one of the

Jinisha Bhatt:

people, and I'll talk about all the positions they hold, one of

Jinisha Bhatt:

the operatives is a person who sets up shop, so his job is

Jinisha Bhatt:

simply to deal with the property manager and create like sign

Jinisha Bhatt:

these documents, and they might even hire a nominee lease,

Jinisha Bhatt:

lease, or lease, or somebody who leases the property. That's

Jinisha Bhatt:

Lisa, right, not leasing. Yes,

Greg Dent:

that sounds right? I get where you're going with

Greg Dent:

this. The person who's actually entering into the lease on

Greg Dent:

behalf of the mortgage it will be, might be one person. They

Greg Dent:

might even hire another layer beneath them to really kind of

Greg Dent:

separate out the actual owner, beneficial owner, of the whole

Greg Dent:

thing, and the person who's actually signing a lease might

Greg Dent:

be two, two levels deep, as it were, is that that's, that's

Greg Dent:

what I'm hearing. Is that cool? Okay, yeah,

Jinisha Bhatt:

and this is a paid job, so now they're making,

Jinisha Bhatt:

say, two or $3,000 a month just for having their name on the

Jinisha Bhatt:

lease. Right now that person, yeah, definitely. That person

Jinisha Bhatt:

who is setting up the shop is buying all the furniture, doing

Jinisha Bhatt:

all these cookie cutter buying all these cookie cutter branding

Jinisha Bhatt:

elements. It's usually the same massage sign and, you know, big

Jinisha Bhatt:

red fonts. You might have seen that the same everywhere they're

Jinisha Bhatt:

getting all the cameras done, they're even buying the Hello

Jinisha Bhatt:

Kitty thing, you know, that goes like this. They all have that

Jinisha Bhatt:

they're dealing with the ATM, and then they leave with so as

Jinisha Bhatt:

soon as they've set up shop, they leave nobody else within

Jinisha Bhatt:

the network knows who they are. I mean, apart from one or two

Jinisha Bhatt:

people, the victim surely don't know who they are, right? So

Greg Dent:

it's a different operator being brought into to

Greg Dent:

run the thing. Okay?

Jinisha Bhatt:

They're really separated from each other. Now,

Jinisha Bhatt:

then this person moves on to the next time, be wherever they're

Jinisha Bhatt:

needed to be. Now, the next person involved in this network

Jinisha Bhatt:

could be the mama San. Mama San, you might have heard the term,

Jinisha Bhatt:

is an older woman who was previously a victim and has

Jinisha Bhatt:

decided to or or has really no financial choice and has to stay

Jinisha Bhatt:

here to manage the other victims now she is arguably still

Greg Dent:

a victim themselves, potentially, he said, formerly a

Greg Dent:

victim, arguably they're still a victim. But carry on. Yeah,

Greg Dent:

yeah.

Jinisha Bhatt:

So the there are two schools of thought about

Jinisha Bhatt:

this. Some people in the industry, in the anti

Jinisha Bhatt:

trafficking world, believe that she's really profiting from

Jinisha Bhatt:

this, and that's the difference between so bottom is like in a

Jinisha Bhatt:

domestic sex trafficking game, bottom or really, the technical

Jinisha Bhatt:

term is bottom. Bitch is actually a victim who is now

Jinisha Bhatt:

promoted to manage the victims, and she doesn't make money. She

Jinisha Bhatt:

doesn't make so much money. She has some privileges, but a mama

Jinisha Bhatt:

San does get to make money because she is incentivized. Is

Jinisha Bhatt:

to now manage five to six victims and manipulate them,

Jinisha Bhatt:

and, you know, get them to not complain and all of that, get

Jinisha Bhatt:

them to cooperate. So she has a job, and that's why she has

Jinisha Bhatt:

incentives. So her job it is to now deal with the victims as

Jinisha Bhatt:

soon as they're brought in, train them, condition them, tell

Jinisha Bhatt:

them what the rules are, but also be this loving, you know,

Jinisha Bhatt:

mother figure, when she needs to be disciplining happens in an

Jinisha Bhatt:

emotionally manipulated, manipulative way. It's never

Jinisha Bhatt:

physical. Now, you must have wondered, but where do the women

Jinisha Bhatt:

come from? So let me introduce you to the third position here

Jinisha Bhatt:

is a recruiter, and I'm actually working on a big investigation

Jinisha Bhatt:

on a recruiter who's been recruiting really explicitly on

Jinisha Bhatt:

X for years. And WeChat women international students from

Jinisha Bhatt:

China, or really women in general, who want to come to

Jinisha Bhatt:

Canada as international students. And he says openly on

Jinisha Bhatt:

x that we will take care of the expenses. You get to come here

Jinisha Bhatt:

and work here, and you get to make money. And there is really

Jinisha Bhatt:

no conversation about school, but he does say international

Jinisha Bhatt:

students in the in the in the x, in the x post or thread. And

Jinisha Bhatt:

we've seen all of these ads on multiple forums that they used

Jinisha Bhatt:

to so this recruiter now is dealing directly with someone

Jinisha Bhatt:

who may be a visa broker, someone who's dealing with the

Jinisha Bhatt:

victims there, who's kind of like a liaison, who's making

Jinisha Bhatt:

sure the victims are coming through, and then he will

Jinisha Bhatt:

receive the victims, and he will bring them to the Mama San,

Jinisha Bhatt:

okay, who's probably going to take their documents, right? And

Jinisha Bhatt:

again, I'm describing the worst of situations here, but this is

Jinisha Bhatt:

how it typically happens. Of course, some victims may then

Jinisha Bhatt:

graduate to workers, and they're still there because they don't

Jinisha Bhatt:

really want to do anything else, but one might argue that they're

Jinisha Bhatt:

not as victimized as fresh victims anyway, so So you you

Jinisha Bhatt:

know all these players. Now, there is one key figure here,

Jinisha Bhatt:

and this is where money laundering begins. So now you

Jinisha Bhatt:

have five to six victims on average, and they are working.

Jinisha Bhatt:

They're seeing 10 to 12 guys a day, for example. They are

Jinisha Bhatt:

primarily accepting cash. So the mama San charges a house fee

Jinisha Bhatt:

could be $60 for the visit, and then inside, this negotiation

Jinisha Bhatt:

happens for what kind of services a person wants. And

Jinisha Bhatt:

because the victim is indebted, she may hand over the tips to

Jinisha Bhatt:

the mama San. She may try to keep some to herself, but

Jinisha Bhatt:

typically she knows that she has a debt to pay. So all of this

Jinisha Bhatt:

cash has to go somewhere. Some imbs may accept credit cards.

Jinisha Bhatt:

They may have different names that come up, but most of them

Jinisha Bhatt:

prefer cash, and so do the guys, right, so do the johns. So some

Jinisha Bhatt:

of them were taking gift cards during COVID that we noticed. So

Jinisha Bhatt:

all this cash, how do you think it gets picked up and then

Jinisha Bhatt:

brought to the bank? Just take a guess.

Greg Dent:

That's a good question. I mean, I'm assuming

Greg Dent:

there's another role here that's gonna pick up the cash and

Greg Dent:

launder it somehow. I guess, if you were in Vancouver, my guess

Greg Dent:

is it goes to a casino and gets lent out as a for those

Greg Dent:

purposes, for gambling, as a loan there, that's a guess. I

Greg Dent:

don't know you tell me

Jinisha Bhatt:

very well might. But I'm also thinking, like, how

Jinisha Bhatt:

similar these enterprises are when it comes to dealing with

Jinisha Bhatt:

the money. I'm thinking El Chapo and how he had people pick up

Jinisha Bhatt:

the cash and, like, move to the bank. And so that's the fourth

Jinisha Bhatt:

or the fifth position. We call him the the money handler. Yeah,

Jinisha Bhatt:

driver. I call him the driver. But many people come the money

Jinisha Bhatt:

handler. He comes to the back door, picks up the cash. He has

Jinisha Bhatt:

no, very little interaction. Mama San literally just slides

Jinisha Bhatt:

the bag of cash to him, picks it up. And then he goes from IMB to

Jinisha Bhatt:

IMB to do that, and then begins the layering. The layering,

Jinisha Bhatt:

yeah, there are just like these people. There might be more

Jinisha Bhatt:

involved. One thing I missed out here when I talked about

Jinisha Bhatt:

collaboration, is who is dealing with all of these companies that

Jinisha Bhatt:

might now be receiving the funds, all these shell

Jinisha Bhatt:

companies, all these holding companies, because now you're

Jinisha Bhatt:

dealing with millions of dollars, so they're not going to

Jinisha Bhatt:

individual accounts. And now you have lawyers, right? And we've

Jinisha Bhatt:

found in some investigations, there is a one lawyer or a group

Jinisha Bhatt:

of small number lawyers, dealing with lot of these people.

Greg Dent:

I am smiling only because as we felt as we tape

Greg Dent:

this, it's been approximately two weeks, roughly since FINTRAC

Greg Dent:

issued a special bulletin on how lawyers might be involved in

Greg Dent:

laundering money just might be and how so many STRS point to

Greg Dent:

that possibility. And yet there's this black hole of

Greg Dent:

information there. So that is fascinating. That really kind of

Greg Dent:

unpacks how to set up the organization and the and and

Greg Dent:

what strikes me is about how many people, and you said this

Greg Dent:

at the beginning, and I think this really kind of gets a level

Greg Dent:

of detail that I'm thankful for, how many people are actually

Greg Dent:

making money in this whole thing? There's, there's six,

Greg Dent:

seven positions before we even start to add in layers of

Greg Dent:

protection that we might use senior, senior victims, for lack

Greg Dent:

of a better description, to further shelter ourselves. Like

Greg Dent:

there's, there's just a lot of people generating what ends up

Greg Dent:

being a lot of money, I can only imagine, and everybody's taking

Greg Dent:

their little cut along the way to be involved in this pretty

Greg Dent:

significantly horrible activity that happens right out in what

Greg Dent:

did you say in plain view? Was that the phraseology? Yeah,

Jinisha Bhatt:

sorry, I have to tell you about a very

Jinisha Bhatt:

interesting position that I failed to mention. Okay, the

Jinisha Bhatt:

paper husband. So suppose a bylaw officer walks in, or the

Jinisha Bhatt:

Ministry of Labor walks in, because, you know, Greg

Jinisha Bhatt:

complained about this IMB. Now what's going to happen is IMB

Jinisha Bhatt:

will the mama son will notice, and she will call her Caucasian

Jinisha Bhatt:

husband, who's only a husband on paper, and his primary job is to

Jinisha Bhatt:

normalize this establishment. So, you know, you think, okay,

Jinisha Bhatt:

like, here's a Canadian guy. He's married to this lady. Maybe

Jinisha Bhatt:

this is a legitimate business. And also, you know, he's aware

Jinisha Bhatt:

of Canadian bylaws and whatnot. And so he's also making a decent

Jinisha Bhatt:

money income from this, just for

Greg Dent:

being a paper husband to show up every now and then

Greg Dent:

and kind of smooth things over, the troubleshooter, as it were.

Greg Dent:

And

Jinisha Bhatt:

if you are in this part of Canada, you know,

Jinisha Bhatt:

near the Greater Toronto Area, we also know there is an RMT

Jinisha Bhatt:

near registered massage therapist, one who is serving

Jinisha Bhatt:

several imbs, issuing all these legitimate receipts for a

Jinisha Bhatt:

massage for insurance fraud. So that's what I mean. If we

Jinisha Bhatt:

collaborate, you'll find not just money laundering, you'll

Jinisha Bhatt:

find insurance fraud. You'll find labor exploitation, all of

Jinisha Bhatt:

that

Greg Dent:

I can charge, pack, Blue, Blue Cross, whatever

Greg Dent:

they're called for my illegal massages, that's insane. Holy

Greg Dent:

crap. Never even occurred to me that that would be but yeah, I

Greg Dent:

guess you start to get into the various tentacles of organized

Greg Dent:

crime, and if everybody can make some money along the way, that's

Greg Dent:

the natural flow of things. All too careful, all too easily.

Greg Dent:

Wow. Well, this has been, like, scary, but also super

Greg Dent:

informative and and so, like, I'm, I'm truly thankful for the

Greg Dent:

the level that you've taken us to in terms of improving my

Greg Dent:

understanding of what's happening in Canada. And you've

Greg Dent:

eloquently, in my mind, answered the question of, does this

Greg Dent:

happen in Canada? It sounds like the question, the answer is a

Greg Dent:

resounding absolutely and and under our noses, as it were, but

Greg Dent:

just as importantly, I think, for us, for me today, what

Greg Dent:

you've done that's that I really want to thank you for is and I

Greg Dent:

hope our listeners will agree, given me some things that I in

Greg Dent:

my day to day might practically be able to just put into my

Greg Dent:

toolkit, into my list of things that I'm looking out for just a

Greg Dent:

little bit that might be able to to help save my through the

Greg Dent:

wrong word, but at least start to highlight where there might

Greg Dent:

be some problems. And I think if we could do just that little

Greg Dent:

bit, certainly what you had talked about was, this isn't a

Greg Dent:

There's no quick solution to this, but the incremental nature

Greg Dent:

of just kind of spreading the word a little bit. And I

Greg Dent:

certainly hope that I certainly feel like you've done that for

Greg Dent:

me. So I hope that our listeners will get that same thing out of

Greg Dent:

out of everything you said, because to me, this has been

Greg Dent:

super helpful and a little bit scary all at the same time.

Jinisha Bhatt:

I appreciate that sentiment scary, but I'm also

Jinisha Bhatt:

it's also scary how impactful we can be, and I'm truly humbled to

Jinisha Bhatt:

know that you care and that you asked, because you know you're

Jinisha Bhatt:

so early on in your AML journey. Lot of people are simply asking,

Jinisha Bhatt:

What are we required to do, and are we doing everything we're

Jinisha Bhatt:

required to do? But this is maybe just a little more, just a

Jinisha Bhatt:

little more and thinking about tangible impact. And I want to

Jinisha Bhatt:

say, once our API is ready, I really would welcome all of you,

Jinisha Bhatt:

the entire industry, to use it to make your SDR reporting much

Jinisha Bhatt:

more accurate. I

Greg Dent:

would love that opportunity, and we'll have to

Greg Dent:

continue to stay linked. That, because I think that's something

Greg Dent:

that I don't know if all of the all of our reporting entities

Greg Dent:

will will want it, but I think it's the kind of thing that I

Greg Dent:

would love to be able to help. Because it just seems to me

Greg Dent:

like, like a no brainer. Why would we not want to stop this

Greg Dent:

level of criminality within our society? Just doesn't make sense

Greg Dent:

to me. So so did you? Thank you so much for taking the time. I

Greg Dent:

know that you've got a busy life of things that involve making an

Greg Dent:

impact. I really, I really want to you to know that I truly am

Greg Dent:

humbled by your willingness to come here to talk with me today,

Greg Dent:

to share all that you have. I thank you so much for that. And

Greg Dent:

yeah, on behalf of our listeners, thank you so much.

Greg Dent:

That's all I can say.

Jinisha Bhatt:

Thank you. This is beautiful. I.

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