Episode 5

The Importance of Suspicious Transaction Reporting in Criminal Investigations

In this episode, Greg is joined by Stephan Scott, a retired RCMP officer with 31 years of experience in organized crime and money laundering investigations. Stephan provides a powerful perspective on the importance of suspicious transaction reporting, explaining how the information gathered by reporting entities like real estate professionals can be crucial in supporting criminal investigations. He shares gripping stories from his career to illustrate how money laundering is deeply connected to serious predicate crimes like drug trafficking and human trafficking. While individual suspicious transaction reports may not directly lead to arrests, Stephan emphasizes that they become part of a larger puzzle that investigators use to uncover criminal activity. He encourages reporting entities to file STRs whenever they have reasonable grounds to suspect suspicious activity, as this information can make a meaningful difference even if the individual impact is not immediately visible. Overall, this episode provides valuable insights into the real-world impact of compliance efforts and the critical role that reporting entities play in supporting law enforcement's fight against organized crime and money laundering

Key Takeaways:

  • Money laundering is not just an abstract financial crime - it is closely tied to serious predicate crimes like drug trafficking, human trafficking, and violent organized crime.
  • The information reported through suspicious transaction reports (STRs) and other financial intelligence can be crucial in informing and advancing criminal investigations.
  • While individual STRs may not directly lead to arrests, they become part of a larger puzzle that investigators use to uncover criminal activity.
  • It is important for reporting entities like real estate professionals to file STRs when they have reasonable grounds to suspect suspicious activity, as this information can make a difference even if the individual impact is not immediately visible.
  • FINTRAC, Canada's financial intelligence unit, analyzes STRs and other financial data to generate intelligence disclosures that are provided to law enforcement to support investigations.

About the guest: Stephen Scott

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. 

Email: stephenscott@sscottamlsconsulting.com


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https://reallytrusted.com/

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Transcript
Greg Dent:

Greg, hello and welcome to another episode of

Greg Dent:

The know your compliance the KYC podcast with me. My name is

Greg Dent:

Greg. I am your host and with me today. I am super excited we

Greg Dent:

have Mr. Stephen Scott. Stephen is a retired RCMP officer. He

Greg Dent:

did 31 years of service in the RCMP, and he's going to come and

Greg Dent:

today, he works in private security, does some anti money

Greg Dent:

laundering investigations, and is kind enough to share with us

Greg Dent:

today some really cool I've had a preview of this, some really

Greg Dent:

cool stories about his work and the way and importantly, and

Greg Dent:

what I want to bring to the podcast today and to you as our

Greg Dent:

audience today, is how important it is for how Steven's stories

Greg Dent:

will highlight for you exactly how much the information you as

Greg Dent:

a reporting entity are gathering, how much it can

Greg Dent:

influence The outcomes of real life, actual criminal

Greg Dent:

investigations. So Stephen, thank you very much for joining

Greg Dent:

us today.

Stephen Scott:

Greg, it's an absolute pleasure to be here. I

Stephen Scott:

always enjoy talking about, personally, my career in money

Stephen Scott:

laundering and organized crime, and sort of sharing that

Stephen Scott:

knowledge, if you will, with various reporting entities. In

Stephen Scott:

this case, you know, real estate focused,

Greg Dent:

yeah, well, so, I mean, I think let me, let me

Greg Dent:

launch right into it. And I think what I had said to you a

Greg Dent:

few weeks ago, when we started talking about this, was one of

Greg Dent:

the questions I frequently get from real estate agents, from

Greg Dent:

real estate compliance officers, and now starting to see from

Greg Dent:

from mortgage brokerages, is all of this stuff, all this

Greg Dent:

paperwork that we need to do, or have been doing, or are going to

Greg Dent:

be need to doing. Why does it all matter? And you have a

Greg Dent:

really great way of getting to an answer. So I thought I'd

Greg Dent:

start with that.

Stephen Scott:

All right, yeah. And if you don't mind, maybe a

Stephen Scott:

bit of a rant, if you will, or the pep talk. I guess to me,

Stephen Scott:

money laundering is more than just sort of that abstract

Stephen Scott:

concept of money being placed, layered, integrated and so on.

Stephen Scott:

And big picture, people like to say it affects the economic

Stephen Scott:

integrity of the country, and it's, it's, it's, it affects the

Stephen Scott:

prices of properties and so on. But really, to me, what's behind

Stephen Scott:

it all are the predicate crimes, the violent crimes, the drug

Stephen Scott:

trafficking, human trafficking, the arms trafficking, any crime

Stephen Scott:

that generates profit, that profit or those earnings need to

Stephen Scott:

be laundered, whether it's to go back into the business, like a

Stephen Scott:

cost of goods sold, to buy more drugs, to pay your employees, to

Stephen Scott:

rent cars, rent stash houses, are leading to the real estate

Stephen Scott:

side, buy properties, even to use to build a meth lab, to have

Stephen Scott:

a marijuana grow, commercial properties from which you want

Stephen Scott:

to wander your money. But to me, the most important thing is, is

Stephen Scott:

people have to remember that it's the violent crimes behind

Stephen Scott:

that. And one of the sayings I have, I'll finish with, is, is

Stephen Scott:

other than crimes of passion and stupidity, it's all about the

Stephen Scott:

money.

Greg Dent:

Yeah, yeah. I mean, you quite rightly start there. I

Greg Dent:

think that's a great place to start, because it's so one of

Greg Dent:

the things I've observed in my work is that money laundering

Greg Dent:

sounds clean. It sounds I think a lot of people think tax

Greg Dent:

evasion is what we're actually talking about. And look, tax

Greg Dent:

evasion is a crime and is it's important when you watch that,

Greg Dent:

sure, but when you start to talk about drug trafficking and

Greg Dent:

murder for hire and drug meth labs and all the rest, then that

Greg Dent:

that like that gets people's attention, generally speaking.

Stephen Scott:

So yeah, no, and I hope it does, because, as I

Stephen Scott:

say, 24 years until the end of my career, has been involved in

Stephen Scott:

organized money laundering. And, you know, I've literally dealt

Stephen Scott:

with killers that we managed undercover operation one year

Stephen Scott:

that involved liquor. Mind you, not, not necessarily real

Stephen Scott:

estate. And the RCMP at the time paid $220,000 cash to buy a

Stephen Scott:

truckload of booze. But the people we bought it from, there

Stephen Scott:

were two of them, and they were hired killers. One guy's record

Stephen Scott:

read manslaughter, stayed murder, withdrawn. Murder stayed

Stephen Scott:

manslaughter, you know, three years. And the other fellows

Stephen Scott:

record was equally as abysmal as violent, violent people. This is

Stephen Scott:

a guy picking up the money on our deal. And you know, to take

Stephen Scott:

that story one step further, we'd done a transaction pages,

Stephen Scott:

$220,000 well, it turns out the agent that was working for us, a

Stephen Scott:

civilian working for the RCMP, and the two bad guys, went up to

Stephen Scott:

a hotel room. They count the money. The money's in bundles,

Stephen Scott:

these $10,000 $5,000 bundles of $20 bills. Well, it turns out

Stephen Scott:

they're $10,000 short. And I'm in the car with the agent

Stephen Scott:

handler, driver, his phone rings, and all of a sudden it's

Stephen Scott:

it's the agent calling, and he says, holy, these guys have a

Stephen Scott:

gun in my head. I'm $10,000 short, man, WTF, in a matter of

Stephen Scott:

words, yeah. And so my guy, and the agent hander, is playing the

Stephen Scott:

role of the truck driver who transacted the deal. Mind you,

Stephen Scott:

he's. As well. Let me pull the truck over. I'll get back in,

Stephen Scott:

you know, we'll figure out what's going on, amongst other

Stephen Scott:

things, we call up the truck driver from there, Bill. It

Stephen Scott:

pulls over. He finds that $10,000 bundle it's hauling out

Stephen Scott:

the bag literally falling out of the he's about 10 kilometers

Stephen Scott:

east of Calgary by that time, and so he turns around, pulls

Stephen Scott:

into the parking lot of the hotel in his big rig, and hands

Stephen Scott:

over the $10,000 to one of these killers. And the guy says,

Stephen Scott:

you're unlucky. You got that money, man. And he shows him a

Stephen Scott:

gun, you know, just under his coat, yeah, which was great for

Stephen Scott:

us with better evidence,

Greg Dent:

uh, well, also better outcome for great agents, yeah.

Greg Dent:

And strangely

Stephen Scott:

enough, the bad guys were taking that money

Stephen Scott:

right to one of our storefront money laundering operations to

Stephen Scott:

get that money turned into an investment or into a check. We

Stephen Scott:

had it covered on both ends. Nice that that's the the crime

Stephen Scott:

behind this that you know people don't see every day is, you

Stephen Scott:

know, people are killed to transact, drug transactions,

Stephen Scott:

liquor transactions, human trend, you know, human

Stephen Scott:

trafficking. And again, I just can't stress that enough that

Stephen Scott:

we're not doing we don't have a compliance regime in Canada and

Stephen Scott:

around the world, because it's a financial problem, it's

Stephen Scott:

organized crime problem, it's a transnational organized crime

Stephen Scott:

problem, and that was recognized back in the late 80s, and

Stephen Scott:

something had to be done. That's the creation of FINTRAC

Stephen Scott:

compliance regimes, reporting entities and so

Greg Dent:

on. That's cool, yeah, no, and that makes sense

Greg Dent:

to me, and I think it's important to start there again,

Greg Dent:

because it highlights the importance of why all of this

Greg Dent:

happens. What would be really helpful is if you could share a

Greg Dent:

story where the intelligence that FINTRAC is gathering helped

Greg Dent:

inform, help direct, help advance a criminal

Greg Dent:

investigation, because that's the other part of things that we

Greg Dent:

don't have a lot of answers for when people are doing this.

Stephen Scott:

Yeah. And strangely enough, or not,

Stephen Scott:

strange enough, I've had that question since, you know, the

Stephen Scott:

2000s when interact was created and whole regime was created, is

Stephen Scott:

people put a lot of time and effort, money and million

Stephen Scott:

scholars in terms of the big financial institutions into

Stephen Scott:

reporting, whether it's large cash transactions, international

Stephen Scott:

EFTS, and most importantly, suspicious transaction reports,

Stephen Scott:

suspicious activity reports in the state's STRS, they form a

Stephen Scott:

piece of a puzzle of a much larger case, and maybe I'll

Stephen Scott:

backtrack. But again, FINTRAC is an intelligence agency, and they

Stephen Scott:

get data from the reporting entities, realtors, financial

Stephen Scott:

institutions, money services, businesses, casinos. It goes

Stephen Scott:

into their system these days because of the sheer volume and

Stephen Scott:

the millions upon millions of transactions that are that are

Stephen Scott:

input. You know, it's machine driven to begin with, if there

Stephen Scott:

are indications of money laundering, spits out the

Stephen Scott:

information that goes to an analyst who looks at this

Stephen Scott:

personally. They do research, whether it's open source,

Stephen Scott:

internet their secret databases, police databases, corporate

Stephen Scott:

registries and so on, land titles registries to all the

Stephen Scott:

provinces. If that analyst determines that the information

Stephen Scott:

provided by these reporting entities reaches the threshold

Stephen Scott:

of reasonable grounds to suspect that money laundering is

Stephen Scott:

occurring, of course, recognizing there's crimes

Stephen Scott:

behind that, they will send this disclosure product to police.

Stephen Scott:

Now that's an intelligence product, and there's a big

Stephen Scott:

difference between intelligence and evidence and information,

Stephen Scott:

and it's important that people know we don't just get, and I

Stephen Scott:

say we, back in the day, the police don't just get a FINTRAC

Stephen Scott:

disclosure automatically start an investigationally, a charge

Stephen Scott:

thing. Everything that comes from the reporting entity to

Stephen Scott:

begin with, has to be corroborated. It has to be

Stephen Scott:

managed, if you will, triage, determined, even if it's going

Stephen Scott:

to become an investigation. So keeping that mind, we get an

Stephen Scott:

intelligence product from from FINTRAC, based on these STRS,

Stephen Scott:

ltrs and so on.

Greg Dent:

That's you for one second there, because what you

Greg Dent:

just said is really important, because one of the pieces of

Greg Dent:

feedback I frequently get from frontline people in many sectors

Greg Dent:

is, well, I don't want to rat out my client. I don't want to

Greg Dent:

rat out this person. And I think what you've just said perfectly

Greg Dent:

illustrates why that's not actually what's happening. It

Greg Dent:

might be true that the intelligence that they provide

Greg Dent:

FINTRAC eventually yields an investigation which eventually

Greg Dent:

finds that this person was guilty of something, but there's

Greg Dent:

not a direct line to your client being arrested just because you

Greg Dent:

filed a suspicious transaction report. It's a pretty involved

Greg Dent:

process, as you've just outlined, absolutely,

Stephen Scott:

yeah, and I got a bit sidetracked from the

Stephen Scott:

original question to get there, I guess. But yeah,

Stephen Scott:

realistically, it's it goes through a lot of stages. And of

Stephen Scott:

course, even within the firm itself, transactions takes

Stephen Scott:

place, whether it's a frontline, frontline real estate agent to

Stephen Scott:

see something wrong, or the money lendering officer in the

Stephen Scott:

brokerage of the business that says, Yeah, I agree with what

Stephen Scott:

this frontline person says. Or it has to get written. It has to

Stephen Scott:

go to FINTRAC, as I say, it goes through, certainly not AI. It

Stephen Scott:

goes through a computer process where the indicators are picked

Stephen Scott:

out, or there's certain terminologies and. I draw their

Stephen Scott:

attention again to the analyst, in some cases, when you say,

Stephen Scott:

does an STR make a difference? Well, an STR could form a

Stephen Scott:

disclosure package, but there might also be four or five or

Stephen Scott:

six other STRS from other institutions. There might be 10

Stephen Scott:

electronics funds transfers. There might be casino

Stephen Scott:

disbursement reports, because a FINTRAC disclosure doesn't

Stephen Scott:

necessarily consist of one STR that goes to FINTRAC and is

Stephen Scott:

given to police. You know, it goes through that analytical

Stephen Scott:

process first. So that's when I say, it's a piece of the puzzle,

Stephen Scott:

if you will, that your STR might just provide a lead that sends

Stephen Scott:

FINTRAC on another direction, that's in turn, they may send

Stephen Scott:

police on another direction that's going to identify an

Stephen Scott:

asset. So as I say, in building on what you said that that

Stephen Scott:

disclosure comes to police. Well, you know, if there's

Stephen Scott:

several 1000 disclosures given to police over the years, you

Stephen Scott:

know, there's only so many resources that can be devoted to

Stephen Scott:

this, and a certain values are taken into consideration as a

Stephen Scott:

big case. This is a small case, so that STR and everything else

Stephen Scott:

that's included with it in that disclosure report is going to

Stephen Scott:

get triaged by police to say, yeah, we'll work on this. Or no,

Stephen Scott:

we won't. We'll file it for some time in the future, and it may

Stephen Scott:

come up in the future as something important, not another

Stephen Scott:

case on a related case, and so on. But even that STR that

Stephen Scott:

FINTRAC disclosure will only be part of a potentially major

Stephen Scott:

project that, you know, takes a year to investigate, and that

Stephen Scott:

results in, to put it visually, you know, bankers boxes full of

Stephen Scott:

documents that we provide in disclosure, it can almost get

Stephen Scott:

buried, you know, in all the information when the bad guy

Stephen Scott:

does get access to it or the lawyers get access to it. So no,

Stephen Scott:

there isn't a direct correlation between the STR and an arrest.

Stephen Scott:

There's no fear of ratting out bad guys. And you got to

Stephen Scott:

remember, too, if I can go on to send an STR you really just have

Stephen Scott:

reasonable grounds to suspect that something's happening,

Stephen Scott:

basically money laundering, or somebody's involved in terrorist

Stephen Scott:

property. That's a very low threshold. It's below balanced

Stephen Scott:

probabilities, which is 51% it's above, you know, having a spidey

Stephen Scott:

sense that this isn't right, but it's something that is not

Stephen Scott:

normal, you know, based on the person's behavior, based on

Stephen Scott:

their transactions, based on the product, goods and services that

Stephen Scott:

they bring to the table or that they want from you. So, yeah,

Stephen Scott:

getting back to that, it's you're not writing anyone out

Stephen Scott:

when you do that, you're just forwarding information that that

Stephen Scott:

is anonymous, or, you know, an anomaly that's not normal that

Stephen Scott:

you think should be investigated further potentially.

Greg Dent:

I really like the puzzle visual, the visual of,

Greg Dent:

you know, maybe I'm the guy who noticed that my client, I don't

Greg Dent:

know, didn't want to get identified. But by putting that

Greg Dent:

in, maybe the bank's got five s5 large cash transaction reports

Greg Dent:

on the same individual, and suddenly you're starting to

Greg Dent:

build a puzzle of information that actually might become

Greg Dent:

useful online. And it's, it's, you know, my view of it is so

Greg Dent:

small that I can't actually see that. When you start to step

Greg Dent:

back and look at the larger thing, I really

Stephen Scott:

like, oh, that's absolutely huge. Greg, almost

Stephen Scott:

exactly two years ago, I went back to work for the police

Stephen Scott:

briefly, and I was talking to our FINTRAC rep here in Alberta,

Stephen Scott:

and he says, Steve, you know, I'm in the middle of putting

Stephen Scott:

together this disclosure. And what those consist of mind, you

Stephen Scott:

are Excel spreadsheets that will detail the, you know, the sender

Stephen Scott:

of transaction, the beneficiary, the depositor, the anything to

Stephen Scott:

do with transaction, basically, the countries and count numbers

Stephen Scott:

and so on. He was saying he was putting together hundreds of

Stephen Scott:

transactions in these spreadsheets and in these i two

Stephen Scott:

charts to send off to the police. So, you know, there

Stephen Scott:

could very well be, you know, 300 STRS from 50 different

Stephen Scott:

reporting entities, or there could be, you know, two or three

Stephen Scott:

STRS, but all of sudden, there's tons of electronic funds,

Stephen Scott:

transfers of money going out, money going out, money going

Stephen Scott:

out, money coming in, that layering that's going on around

Stephen Scott:

the world. But it's that STR that may push that analyst over

Stephen Scott:

the edge to say, someone thinks this is suspicious, and maybe

Stephen Scott:

these two other people think this is suspicious, that's what

Stephen Scott:

gets the attention of FINTRAC international funds transfers,

Stephen Scott:

$10,000 transactions and electronic funds transfers.

Stephen Scott:

There's billions of dollars transacted every day. They

Stephen Scott:

don't, they don't attract anybody's attention. But that

Stephen Scott:

STR does well,

Greg Dent:

and the STR compiled with all of that financial data

Greg Dent:

and the money flows that come with it might actually paint a

Greg Dent:

wholly different picture than you might have other or that I

Greg Dent:

don't have otherwise. And

Stephen Scott:

to quickly put that in different terms, I guess

Stephen Scott:

what I was trying to say, because I don't say anything

Stephen Scott:

short, is they may have all this information database that isn't

Stephen Scott:

necessarily suspicious, because you have to report these

Stephen Scott:

transactions to threshold transactions, but all of a

Stephen Scott:

sudden an STR or two or three come in, because the fellow may

Stephen Scott:

be doing or the bad guy may be doing a number of transactions

Stephen Scott:

with a number of different people that may be suspicious.

Stephen Scott:

That is what triggers, effectively, the disclosures, if

Stephen Scott:

anything or there is important or more important than anything

Stephen Scott:

else. Yeah, so

Greg Dent:

I want to, I want to continue that smile. I just want

Greg Dent:

to put an asterisk for a second, because what you've just said is

Greg Dent:

really important for compliance officers to hear, and what I've

Greg Dent:

observed and where we've seen some. Some small businesses get

Greg Dent:

into problems with FINTRAC with their compliance regime,

Greg Dent:

specifically is if some other reporting entity has filed a

Greg Dent:

suspicious transaction report, or has in some way, shape or

Greg Dent:

form, identified a transaction that should have been

Greg Dent:

suspicious, and then a FINTRAC shows up and examines your books

Greg Dent:

and there's nothing that's when FINTRAC is going to make sure

Greg Dent:

you have a very bad day. And the reality is, a certain amount of

Greg Dent:

that might be defensive filing, sure, maybe. But my advice, I

Greg Dent:

suppose, is, or where I'm trying to get to with this statement,

Greg Dent:

is, it would be in your best interest as a reporting entity

Greg Dent:

to file when you think you might have reasonable grounds to

Greg Dent:

suspect, because if you don't file, you will have a much worse

Greg Dent:

day than if you file and you're wrong, is what

Stephen Scott:

that's the prevailing thought, actually,

Stephen Scott:

yeah, and it's funny, I see that from both ends. You know, as an

Stephen Scott:

investigator, I want everything. I want more. Give me more. It's

Stephen Scott:

morally right to do this, and for all the other reasons I talk

Stephen Scott:

about, as a person who's worked with with variance, compliance

Stephen Scott:

people as well. Over the years, I see that it's sometimes hard

Stephen Scott:

to do, or it seems like it takes a long time, or there's a cost

Stephen Scott:

to do business, or you don't see the result at the end of the

Stephen Scott:

day. So we ask, why did we do this? But realistically, it

Stephen Scott:

doesn't take that long to fill in one of those reports online.

Stephen Scott:

You know, it's core biographical data, facts, context and

Stephen Scott:

indicators, and along the same lines. You know, every major

Stephen Scott:

police investigation sends in what we call a voluntary

Stephen Scott:

information record to FINTRAC. They're exactly like STRS, and

Stephen Scott:

minimize that. We're working on a money laundering investor or

Stephen Scott:

direct traffic investigation. We've identified assets. We

Stephen Scott:

think this person is laundering money. This is their core

Stephen Scott:

biographical data accounts that we know of. Maybe we've done

Stephen Scott:

some production orders, maybe we've done surveillance,

Stephen Scott:

wiretaps. You put all that in there realistically, and I put

Stephen Scott:

in dozens, it's 10 or 15 minutes, not even 1015 minutes.

Stephen Scott:

And that's all that FINTRAC, you know, really demands that if you

Stephen Scott:

fill out an STR it's not going to take too long. And I think

Stephen Scott:

you're better off doing it than not, because, yeah, they're

Stephen Scott:

coming down. And I still say, hey, talk to people on FINTRAC,

Stephen Scott:

and I see them quite a bit online, and I've seen the amps,

Stephen Scott:

the administrative monetary penalties are coming out.

Stephen Scott:

They're starting to crack down. They've hired more people there.

Stephen Scott:

There's more issues. Money laundering in real estate is

Stephen Scott:

much more out there than it used to be. There's greater awareness

Stephen Scott:

of it. To call them Commission, the Mulroney report. It's in

Stephen Scott:

television. It's at the FATF reports. I was reading something

Stephen Scott:

from 2006 this morning when it was, you know, described as a

Stephen Scott:

problem back then. And now Canada's catching up with that,

Stephen Scott:

I guess because of the the negative press we're getting

Stephen Scott:

around the world, if you will. Yeah, that's problem. So, yeah,

Stephen Scott:

if you think you should do it, there's no harm in doing it,

Stephen Scott:

because, as I say, from an investigator's perspective, and

Stephen Scott:

this, what it's all done for, is to, you know, take that, that

Stephen Scott:

monetary reward, away from these bad guys, and they launder their

Stephen Scott:

money. To do that, to buy assets, to buy toys, to to live

Stephen Scott:

a certain lifestyle, put it in there. It may make a difference.

Stephen Scott:

And it will say to you, the the wrath of FINTRAC, if you will,

Stephen Scott:

here and you just

Greg Dent:

touched on something, I'm hoping we could go a little

Greg Dent:

deeper on, which is, could you walk me through how this

Greg Dent:

information as an investigation, as an investigator, sorry, put

Greg Dent:

yourself back in your shoes as an investigator. Where those

Greg Dent:

where that FINTRAC data has been helpful for you in guiding an

Greg Dent:

investigation, or where maybe it's informed your investigation

Greg Dent:

or even moved it forward, I suppose,

Stephen Scott:

sure. Um, preface out with as we spoke the other

Stephen Scott:

day, there haven't been a great deal of suspicious transaction

Stephen Scott:

reports submitted from the real estate industry last bunch of

Stephen Scott:

years fully acknowledged. Yeah, I can't say to all of us here

Stephen Scott:

that I've even seen an STR related to real estate in dozens

Stephen Scott:

and dozens and dozens, I'll say several 100 disclosures that

Stephen Scott:

involve that, but that said they exist. And I know there's more

Stephen Scott:

and more, and there's been a lot more since I've retired

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