The FIFA World Cup is poised to be a transformative economic event for Canada. With transformative events come wide-ranging risks in crime.

According to FIFA's pre-tournament Economic Impact Assessment, developed by Deloitte Canada, the tournament is estimated to contribute up to CAD 3.8 billion in total economic output for Canada, including CAD 2 billion to GDP, CAD 1.3 billion to labour income, and approximately 24,100 jobs. The World Travel & Tourism Council forecasts that Canada's tourism GDP will grow by 6.4% in 2026, the strongest projected growth among the three co-host nations, with more than 300,000 visitors expected in each of Toronto and Vancouver. Globally, the tournament is projected to contribute over $40 billion in GDP worldwide.

While this economic activity presents enormous opportunity, it also creates conditions in which financial crime and human exploitation can proliferate. The scale of the event, the volume of transactions, and the concentration of temporary labour and services demand heighten the risk environment for money laundering and human trafficking.

With the FIFA World Cup 2026 set to kick off in Canada, the US and Mexico in the coming days, businesses operating in Canada should be aware of heightened compliance risks associated with major international sporting and entertainment events.

On the heels of the FIFA World Cup , the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) has issued a Special Bulletin on human trafficking risks associated with major international sporting and entertainment events (the “Bulletin”), which provides strategic intelligence concerning the laundering of proceeds derived from human trafficking linked to large-scale events of this nature. The Bulletin highlights practical risks that businesses operating in connection with the World Cup should have on their radar.

Elevated risks associated with the World Cup

Major international sporting and entertainment events can draw hundreds of thousands of visitors to host cities—Toronto and Vancouver in this case—driving surges in economic activity across hospitality, entertainment, transportation, and tourism. These conditions can make criminal activity, including money laundering and human trafficking, more difficult to detect.

Key risks: Money laundering and human trafficking

Human trafficking, whether for the purpose of sexual exploitation or forced labour, is a profit-driven crime that generates illicit proceeds requiring concealment, movement, or integration into the financial system. In Canada, human trafficking is prohibited by the Criminal Code and the Immigration and Refugee Protection Act (“IRPA”).

Section 279.01 of the Criminal Code prohibits human trafficking and criminalizes a wide range of conduct rooted in evidence of exploitation. The provision reads that “every person who recruits, transports, transfers, receives, holds, conceals or harbours a person, or exercises control, direction, or influence over the movements of a person, for the purpose of exploiting them or facilitating their exploitation” is guilty of an indictable offence.

The offence is punishable for a maximum period of life imprisonment or a minimum period of imprisonment for five years where a kidnapping, aggravated assault, aggravated sexual assault, or death, is caused during the commission of the offence. In all other human trafficking cases, the offence attracts a mandatory minimum four-year period of imprisonment or a maximum period of fourteen years imprisonment.

Proof of exploitation does not require evidence of profit-driven motives, and consent is not a valid defence.

However, proof of exploitation, according to Canadian criminal law, does not require evidence of profit-driven motives. Merely requiring an individual to provide a labour or service that could cause that  person to fear their safety or the safety of someone known to them if they failed to provide the service or labour, constitutes exploitation.

Exercising control, direction, or influence can include a broad spectrum of power over another’s ability to move freely (R. v. TJF, 2024 SCC 38).

Other trafficking-related offences in the Criminal Code include:

  • Trafficking of a person under 18 years of age (section 279.011).
  • Receiving a financial or material benefit from trafficking a child or adult (section 279.02).
  • Withholding or destroying a person’s identity or travel documents (section 279.03).

Under the IRPA, it is an offence to organize the entrance of individuals into Canada through abduction, fraud, deception, or the use/threat of force or coercion.

What businesses should watch for

The Bulletin sets out a comprehensive set of indicators to assist reporting entities in identifying suspicious transactions. These span three key areas:

  1. General and contextual indicators (such as geographic concentration of activity near event venues and elevated cash usage).
  2. Suspicious account and payment activity (including unusual peer-to-peer payment spikes, centralized account control, and transfers to virtual currency exchangers).
  3. Suspicious payroll and business activity (such as suppressed payroll, disproportionate deductions, and round-dollar wage withdrawals). Businesses should consult the Bulletin directly for the full list of indicators.

Practical considerations for all businesses

Businesses that are not FINTRAC reporting entities should be alert to the risks outlined above. The FIFA World Cup will bring a significant influx of visitors and short-term economic activity, and businesses in hospitality, transportation, security, construction, and food services may encounter situations involving potential human trafficking or money laundering.

Businesses should consider reviewing their existing compliance programs, risk assessments, and employee training to ensure they are calibrated for the unique risk environment created by a major international event.

FINTRAC reporting entities

Businesses that are reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the “PCMLTFA”) bear particular responsibility during events of this magnitude. FINTRAC has encouraged reporting entities to consult its additional published guidance as a complement to the Bulletin.

The list of reporting entities is broad and includes banks, credit unions, trust and loan companies, life insurance companies, money services businesses, real estate brokers and developers, securities dealers, casinos, dealers in precious metals and stones, accountants, and mortgage brokers and lenders, among others. Since 2025, this list has been expanded to include cheque cashers, factors, financing or leasing entities, and title insurers. On a practical level, FINTRAC reporting entities can take the following steps to strengthen their compliance with the PCMLTFA and its associated regulations:

  • Review and consider how your anti-money laundering and anti-terrorist financing program may be affected by these evolving risks, including reporting obligations to FINTRAC.
  • Consider whether your compliance policies and procedures manual reflects the specific risks relevant to your business and sector, including those heightened by the World Cup.
  • Pay particular attention to event-related risks such as increased cash transactions, temporary labour arrangements, and geographic concentration of activity around World Cup venues, and whether these risks are captured in your risk assessment.
  • Review record-keeping practices required under the PCMLTFA, including maintaining records of transactions, client identification, and any suspicious activity, to ensure a clear audit trail and support the timely filing of reports with FINTRAC.
  • Train all relevant staff, particularly those in client-facing and transaction-processing roles, to recognize the indicators of money laundering and human trafficking identified by FINTRAC, and ensure training is refreshed in advance of the World Cup period.

Takeaways

The FIFA World Cup 2026 presents an extraordinary opportunity for Canada, but it also brings a heightened risk environment from a financial crime and human exploitation standpoint. FINTRAC's Bulletin is a timely reminder that both reporting entities and the broader business community must remain vigilant, review their compliance programs, train their staff on the relevant indicators, and report suspicious activity promptly.

Our experienced team is available to assist with any questions regarding your obligations under the PCMLTFA or with general guidance around compliance during similar events. If you have any questions please contact the authors or a member of our Financial Services Regulation, White Collar Defence & Investigations, and Entertainment & Sports Law groups.