A decade in, BMO-led Project Protect gets fresh teeth from Canada's AML watchdog
FINTRAC has issued new money-laundering indicators for reporting entities to apply during major sporting and entertainment events, a decade into Bank of Montreal-led Project Protect.
The Financial Transactions and Reports Analysis Centre of Canada published the Special Bulletin (FINTRAC-2026-SB003) on May 28, 2026, telling businesses subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act how to spot transactions tied to human trafficking - both sexual exploitation and forced labour - in the days around large gatherings that draw hundreds of thousands of visitors to host cities.
FINTRAC says reporting entities should consider the bulletin and related resources when developing and refining risk assessments, applying enhanced measures to mitigate identified risks, and maintaining ongoing compliance training programs.
The bulletin marks ten years of Project Protect, a public-private partnership led by the Bank of Montreal and supported by Canadian law enforcement agencies and FINTRAC. Launched in 2016 to focus on sexual exploitation, the initiative has since expanded to include forced labour.
In 2024-25, the agency generated 316 disclosures of actionable financial intelligence on human trafficking to municipal, provincial and federal law enforcement, identifying 538 subjects of interest and supporting 26 project-level investigations. FINTRAC also produced 6,236 financial intelligence disclosure packages, based on 2,730 unique disclosures, in support of investigations of money laundering, terrorist financing, sanctions evasion and threats to the security of Canada, contributing to more than 200 major, resource-intensive investigations in the past year.
The bulletin points reporting entities to transaction patterns that may take on greater significance when assessed alongside event timing and other contextual indicators: incoming peer-to-peer payments from multiple unrelated individuals during the lead-up to a major event, followed by rapid withdrawals; payments for online escort advertisements made by a single account holder on behalf of others; and clusters of accommodation expenses paired with late-night automated banking machine withdrawals in event-host cities. For labour trafficking, the bulletin flags payroll income credited to multiple workers and rapidly transferred to a common account, plus deductions described as recruitment fees, work-permit costs or LMIA expenses borne by the worker rather than the employer.
A single indicator is not enough on its own. FINTRAC says reporting entities should weigh the signals together and against what they know about the client, and submit a suspicious transaction report when reasonable grounds exist. The agency wants those reports flagged with #Project PROTECT or #PROTECT in Part G to speed disclosure.
Acting Director and Chief Executive Officer Stéphane Sirard said human trafficking is a devastating crime that often thrives in moments of heightened activity, including major international sporting and entertainment events, and called for coordinated action between public authorities and the private sector to deny traffickers the ability to profit from exploitation.
The bulletin's list of international resources includes a FinCEN Notice on the Threat of Human Trafficking During the 2026 FIFA World Cup.
