WASHINGTON — A former senior U.S. intelligence official has concluded that an “unprecedented crime convergence” is underway across Canada, involving nearly 700 organized crime groups operating in strategic cooperation and networked into 48 countries—amid virtually no coordinated national response from Ottawa—resulting in potentially hundreds of billions of dollars laundered in the country each year.

Beyond this groundbreaking assessment of the scale of drug money laundering through Canada, the Washington-based expert finds that these expanding criminal operations were accelerated and empowered by the Liberal government’s 2016 decision to drop visa requirements for Mexico.

The hard-hitting study, produced by David M. Luna through the International Coalition Against Illicit Economies, asserts that U.S. government assessments on Canada’s growing role as a transnational hub of poly-narcotics production, trafficking, and—more importantly—money laundering are more detailed and plausible than Ottawa’s own data releases.

The consequence has been the rapid formation of what Luna describes as “an integrated ecosystem of criminality and corruption” operating within Canadian borders and Indigenous First Nation territories, involving key transnational networks—most importantly Chinese Triads and the Sinaloa and Jalisco New Generation Mexican cartels.

Critically, the findings illuminate the structural role of domestic figures like former Olympian Ryan Wedding: powerful Canada-based biker networks, including the Hells Angels, have become key enforcers and intermediaries between Chinese, Mexican, and Iranian transnational crime networks and Canadian street-level drug dealers.

“Canada has become a safe zone for the world’s most notorious crime groups and threat networks. It is not merely a consumer of illicit goods and contraband, but increasingly serves as a hub of illicit trade, production, and distribution of illicit goods, an exporter of such contraband, and a money laundering safe haven for a potpourri of sinister malign networks,” Luna writes.

“These illicit activities have a disrupting and destabilizing impact on Canadian political, governance, security, and business structures,” his report finds. “In fact, across Canada, criminal networks continue to profit handsomely from an array of illicit activities that are endangering the health and safety of its citizens, and are imperiling the country’s national security and threatening global peace.”

The report affirms much of The Bureau’s recent investigative reporting on the convergence of organized crime and foreign interference in Canada, while delivering a conclusion that reframes the crisis: the fentanyl epidemic devastating Canadian communities, and the border vulnerabilities that enable it, are critical—but they are symptoms.

The deeper threat, Luna argues, is Canada’s role as a money laundering platform for these transnational networks.

In this analysis, drug trafficking revenue is not merely a commodity to be cleaned and banked by international crime groups. It is the capital—or liquidity, as financial analysts might say—that provides fuel for multiple sectors of both the legal and illegal economy. In this new light, drug trafficking and money laundering aren’t ends to themselves. They are the operating system.

Luna’s new study, an ongoing series through ICAIE’s Illicit Shadows project, represents one of the most comprehensive public mappings yet attempted of Canada’s criminal infrastructure—and by a figure with direct experience inside the U.S. intelligence and law enforcement architecture.

Luna, who served 22 years in U.S. government including as Assistant Counsel to the President and in multiple senior directorships at the State Department’s Bureau of International Narcotics and Law Enforcement Affairs, identifies a criminal ecosystem in which the most powerful transnational organizations on earth—Chinese triads and CCP-linked money laundering syndicates, Mexican cartels, Iranian crime networks, Punjabi gangs, the Hells Angels, Eurasian mafias, and Aboriginal criminal groups—are not competing, but rather collaborating. At scale. Across every province and territory.

“Taken together, available estimates by both governments in Canada and the United States, it is fair to state that Canada is awash with tens of billions of dirty monies from an array of criminal activities and corruptive influence operations that are laundered and reinvested every year across its formal sectors and industries,” Luna writes.

“The biggest cross-border criminal security threats to Canada and the US are the staggering amounts of dirty money that is laundered in both countries by Mexican cartels, Chinese money laundering syndicates, and other transnational criminal organizations that finance greater insecurity and instability.”

Luna traces the acceleration of cartel infiltration to a specific policy decision. The 2016 lifting of the Mexican visa requirement under Prime Minister Justin Trudeau, his assessment finds, enabled hundreds of cartel members to enter Canada and establish operations freely. The Sinaloa Cartel and Jalisco New Generation Cartel — which Luna designates the “most dangerous” transnational criminal organizations in North America — have since expanded from supply into direct production, establishing fentanyl synthesis labs on Canadian soil and building distribution networks in partnership with domestic criminal organizations including the Hells Angels.

But the cartels operate below an upstream force.

Chinese transnational crime syndicates play what Luna calls “a central role in financing and laundering the proceeds of the drug trade in Canada,” managing networks that disguise cartel profits through casinos, real estate transactions, underground banking systems, and cryptocurrency exchanges. Vancouver and Toronto are identified as the primary hubs for these operations, with laundered proceeds moving undetected across international financial systems. Luna positions these CCP-adjacent networks not as one player among several but as the predominant upstream factor — the financial oxygen without which the ecosystem cannot function.

Iranian crime organizations, less visible but strategically significant, have established control over fentanyl trafficking’s financial and cybercrime sectors, facilitating cross-border laundering through sophisticated transaction schemes. Iranian financial elements are also linked to the trafficking of precursor chemicals used in fentanyl production. Punjabi gangs have emerged as major players in a billion-dollar supply network trafficking heroin and methamphetamine from India through Canada to North America and Europe.

The Hells Angels serve as the critical domestic intermediary — handling local distribution and enforcement across urban and rural markets, ensuring that product supplied by international networks reaches Canadian street dealers.

One of Luna’s most pointed findings concerns trust.

In building ICAIE’s Canada Illicit Economies Project, Luna found that U.S. government assessments of illicit markets inside Canada were consistently more credible and more granular than anything produced by Ottawa. Canadian authorities, he reports, could provide seizure data — and almost nothing else.

“There was the dearth of quality data provided by the Government of Canada,” Luna states. “I was disappointed that besides seizures, we could not get any official data points on estimates for the overall size and scales of today’s illicit markets in Canada and their specific dollar amounts.”

“What is alarming,” he continues, “is that seizures only show a minuscule level of criminality and strategic corruption in Canada, and in fact the scales of illicit markets in Canada are closer to various USG estimates.”

The Canadian Security and Intelligence Service has publicly estimated that $36 billion to $91 billion is laundered and integrated into Canada’s economy annually. But that figure comes with no breakdown by predicate crime, no specificity by illicit market, and no accounting for embezzled funds reinvested in the country.

ICAIE’s own projection, drawing on U.S. government intelligence and open-source analysis, is that the real figure could be several times the CSIS estimate — potentially reaching into the hundreds of billions of dollars annually. A 2022 U.S. State Department report assessed that tens of billions are laundered in Canada every year from drug trafficking, fraud, corruption, counterfeiting, piracy, and tobacco smuggling. The TD Bank scandal — in which the institution admitted its lax controls allowed fentanyl traffickers to launder at least $670 million — represents just one bank and one pipeline among many.

For a Five Eyes partner, the implication is damaging: Washington is producing a more reliable intelligence picture of Canada’s domestic criminal economy than Canada itself, in Luna’s telling.

Western Hemisphere Trafficking Runs Through Great Lakes Crossings

The scope of the infrastructure Luna documents is continental.

His assessment, produced jointly with the Council of the Great Lakes Region, maps drug flows, smuggling methods, border vulnerabilities, and laundering channels across the full U.S.–Canada corridor.

His boiled-down assessment presents a narrative of what has emerged, and what is foreshadowed, if Ottawa doesn’t meaningfully act.

“Local distribution is dominated by outlaw motorcycle gangs, with the Hells Angels being the most influential. They act as a critical intermediary, handling local distribution and enforcement within Canada, ensuring the product moves through urban and rural markets,” Luna writes. “This ecosystem demonstrates that organized crime is adopting corporate-style models. They are using alliances to expand their illicit operations, forming a sophisticated North American criminal ecosystem. They have the product and the power. Now, they need a place to wash the billions of dollars soaked in blood.”

The place for the Western world has now become Canada, is Luna’s unsparing conclusion.

Among the findings:

Drug flows into Canada originate primarily from two sources. Mexican cartels supply cocaine, heroin, and methamphetamine across the U.S. border. China supplies fentanyl precursors and pill presses — both to Mexico and directly to Canadian labs. Luna found based on available data that the vast majority of fentanyl has flowed from Mexico into the United States, rather than from Canada’s northern border, although other U.S. experts say they believe fentanyl shipments moving from Vancouver’s port into western U.S. ports represent a growing and largely unreported trafficking route.

Drug flows out of Canada mark a critical shift. Canada-produced fentanyl is largely for domestic consumption, but significant quantities are now trafficked to Australia, parts of Asia, and New Zealand. Synthetic opioid shipments leave via air cargo, postal services, and maritime routes. Domestic fentanyl and nitazene production is increasing, driven by Mexican cartel expansion onto Canadian soil. Canada has graduated from consumer to exporter.

The Great Lakes region is the geographic epicenter. Spanning eight U.S. states, two Canadian provinces, and Indigenous Nations, it has a combined GDP of nearly $6.87 trillion and handles more than 50% of U.S.–Canada cross-border trade. In 2024, 86% of illegal crossings from Canada into the U.S. occurred in this region. The Swanton Sector accounted for 82% of those crossings — primarily through Roxham Road, the International Railway Bridge, and Akwesasne First Nations territory. Detroit, Buffalo, Toronto, Montreal, and Chicago are primary trafficking points. Vancouver, Calgary, Toronto, and Montreal serve as cartel-controlled distribution hubs.

The smuggling methods are industrial. Hidden vehicle compartments in commercial trucks. Cargo containers with narcotics mislabeled as legitimate goods. Drug mules at airports. Small parcels flooding USPS, FedEx, UPS, and DHL to avoid bulk seizures. Human smuggling operations across land borders. E-commerce platforms, postal services, and air cargo exploited with increasing sophistication.

The laundering architecture runs through six channels: real estate fraud — particularly high-value property purchases in Toronto, Vancouver, and Montreal; casino-based laundering in British Columbia and Ontario, where illicit cash is exchanged for chips and cashed out as “winnings”; trade-based laundering through over- and under-invoicing of legitimate goods; Chinese underground banking systems and cryptocurrency exchanges; shell companies enabling cross-border transfers; and e-commerce and postal platforms used to move small, high-value shipments and launder profits under legitimate cover.

The human cost is staggering. Between 2016 and 2024, there were 49,105 opioid-related deaths in Canada, with 84% of 2024 fatalities in British Columbia, Alberta, and Ontario. Fentanyl seizures surged 775% in 2024. Cocaine seizures increased 168%. Luna frames this not as a public health crisis with criminal dimensions, but as a criminal enterprise with catastrophic public health consequences.

That distinction arguably determines whether the response is treated as a medical challenge—or a national security imperative.