Speech at the Canadian Institute's 25th Annual Canadian Forum on Anti-Money Laundering and Financial Crime by Deputy Commissioner of Supervision and Enforcement Frank Lofranco

June 10, 2026

Toronto, Ontario

Check against delivery

Moving together: A System Wide Response to Financial fraud

Good morning and thank you for the invitation to join you today. It’s a pleasure to be back at this event after several years, especially because earlier in my career, in anti-money laundering roles, this conference was a regular and valued part of my calendar.

And returning this year feels especially timely, because tomorrow, as the FIFA World Cup begins, much of the world will be talking about form, talent, and tactics. And what we are sure to witness is team performances that showcase what is known as total football.

As some of you in this audience know, I am a fan of the Beautiful Game. And I did play when I was younger. And let’s just say it was in a different body and well before the introduction of virtual assistant referees.

For those who do not spend their time immersed in football—or soccer—"total football” was most famously associated with the Dutch teams of the 1970s. It described a style of play in which no player was confined to a single fixed role; movement, anticipation, and shared responsibility mattered as much as individual brilliance.

The idea was simple but radical: when the game shifts, the whole team shifts with it—covering space, closing gaps, and adapting in real time.

That may seem like an unusual starting point for a conference on anti-money laundering and financial crime. But it is a useful metaphor for the challenge in front of us.

And it should not surprise you that the challenge I am referring to is consumer-targeted fraud—where the harm is often most immediate, most personal, and most visible to Canadians.

And, as you are undoubtedly aware, today, fraud does not stay in one place. It moves swiftly across products, institutions, sectors, and jurisdictions. And a static, fixed, and single response will always be too slow and too late.

So today, as the World Cup begins, total football offers more than a sporting metaphor. 

It offers a way of thinking about the challenge before us, because an effective response to financial fraud requires a system that can move together—anticipating risk, preventing harm, and ensuring accountability across the systems of which you are a part.

I’ll make the case for a systems-thinking approach in four parts—let’s call them Key Takeaways.

First, I’ll start with FCAC’s specific role in this landscape: how our supervision, research, and consumer education efforts can contribute to the broader system response.

Second, I’ll turn to the state of consumer-targeted financial fraud today, focusing on the key realities that must inform our response. A set of reality checks, if you will.

Third, I’ll look at how that response is currently evolving, including Canada’s National Anti Fraud Strategy and the implications of recent federal measures to combat fraud.

And finally, I’ll close with the shared outcomes we should be working toward, together—across regulators, industry, law enforcement, and all the partners and stakeholders represented in this room.

FCAC’s role and why it matters in combatting fraud

Let me start with FCAC’s role.

First, and foremost, we are a supervisor. We supervise the compliance of federally regulated financial institutions—primarily banks— with their consumer protection obligations.

This includes consumer protections specific to unauthorized debit and credit card transactions—protections that span legislation, codes of conduct, and public commitments.

Debit cards and credit cards are unique among financial products, unique because they both have liability protections for fraudulent transactions.

As I will come back to shortly, the government has introduced amendments to strengthen and extend these long-standing protections as an initial step to combat fraud.

Beyond supervision, FCAC also plays a key role in research, education, and financial literacy.

We study fraud trends and impacts, and we work with partners to raise awareness and help Canadians protect themselves.

There’s an important principle embedded in that last point.

Consumer awareness is necessary, but insufficient. Education should be positioned as complementary to system wide safeguards and enforceable protections, not as a substitute for them.

That distinction matters, because fraud today is not simply a “consumer vigilance” problem.

Fraud is increasingly a design, accountability, and coordination problem, across institutions, across industries, and across governments.

And that’s why FCAC’s role matters: we bring oversight, evidence, and consumer insight together to identify where the system is falling short and help drive more consistent, effective protections for consumers.

The state of fraud today: Four realities to inform our response

Reality check time: So, what does the fraud environment look like today?

Let me offer four realities, each with a lesson for anyone working in anti-money laundering and responding to financial crime and fraud.

Reality Number 1: Fraud is now systemic.

It is organized. It is sophisticated. It is evolving quickly. Some would say at an alarming rate.

According to the Canadian Anti-Fraud Centre, in 2025 alone, reported losses in Canada reached $704 million, up from $645 million the year before. And more than 300 percent higher than losses reported in 2020.

These figures likely understate the true scale.

As the Canadian Anti-Fraud Centre itself has noted, reported cases likely capture only a small share of total fraud.

If only 5 to 10 per cent of fraud is reported, then the true losses are not in the millions—they are in the billions.

The channel mix also matters, with significant losses tied to digital payments.

Again, using Canadian Anti-Fraud Centre reporting for 2024, wire transfer fraud accounted for about $154 million, while Interac e Transfer fraud accounted for about $36.7 million. But once underreporting is considered, both channels represent losses on a much larger scale.

What this tells us is that fraud is not showing a temporary spike—it reflects sustained, structural growth of about 10 per cent a year.

Behind these numbers are real and often prolonged impacts—whether it’s a widow’s lost pension money, a senior losing a lifetime of savings, or funds diverted over months of fraudulent transactions.

What makes this possible is not a single vulnerability, but an inter-connected system that fraudsters exploit:

• they exploit the speed and reach of digital payments
• they exploit the trust consumers have in financial institutions
• and they exploit fragmented oversight across financial entities, payment systems, levels of governments, and sectors in our economy

The lesson here is that fraud is not a one off event.

And when a threat spans multiple sectors, any response that remains sector by sector or institution-by-institution will always be late and will always be ineffective.

Turning to reality Number 2: Clear warning signs are not being acted on, or are being missed entirely.

Again, it’s a systems issue:

•  limited information-sharing prevents timely detection and coordinated intervention
• uneven or unclear liability frameworks weaken incentives to prevent, detect, and respond quickly
• and diffused and fragmented accountability across institutions, sectors, and jurisdictions make coordinated action difficult

The lesson here is that inadequate protection against fraud often reflects system weaknesses, hindering timely detection, intervention, and effective prevention.

Let me turn to a third reality: some consumers are bearing disproportionate harm, especially the most vulnerable.

Indeed, FCAC’s research shows that fraud affects everyone, but different groups experience different risks.

Phishing and unauthorized card use are more commonly reported by women and seniors, while men and younger Canadians are more vulnerable to investment fraud.

Fraud is increasingly hitting those least able to absorb the loss, often pushing them into financial hardship.

The lesson here is that effective protection is measured by how well protections serve those most at risk.

Finally, reality Number 4: Accountability is often reactive, driven by escalation rather than built into the system.

This is the most unsettling point and one of the most important.

In too many real-world cases, the need for accountability emerges only after issues attract media attention, trigger complaints, result in litigation, or draw political scrutiny.

As a regulator, we raise these concerns in our discussions with industry.

A system that depends on escalation, public pressure, or moral suasion to deliver fair outcomes is not a system that predictably protects consumers.

The lesson here is simple. Accountability should be built in. It should not be triggered after the fact.

That is why many jurisdictions around the world are now pointing to the need for more structured, upfront protections—clearer rules, stronger incentives, and more consistent accountability.

Taking action

Fraud is not solely a Canadian problem, it is a global problem.

The OECD Consumer Finance Risk Monitor, which I recommend you add to your reading list, was published this past March, and found that the large majority of countries identify fraud as the top risk facing financial consumers.

So, what is being done? What actions are being taken?

We are seeing jurisdictions such as the United Kingdom, Ireland, Australia, and Hong Kong taking action. These countries are:

• strengthening consumer protection frameworks, including liability and remediation mechanisms
• expanding information sharing across sectors in the economy, including with telecom and online platforms
• and investing in real-time detection and real-time intervention capabilities

In Canada, the federal government is developing a National Anti-Fraud Strategy.

In the more immediate term, an important milestone was the recent passage of Bill C 15, which is creating new regulatory obligations for Canadian banks to address consumer targeted fraud, obligations that FCAC will supervise and enforce.

Let me highlight these for you. There are new legal obligations:

• to establish and adhere to policies and procedures to detect and prevent fraud, and mitigate its impacts
• to obtain expressed consent from consumers before enabling certain account features and permitting consumers to disable unwanted account features
• to allow consumers to adjust transaction limits attached to their accounts
• and lastly, to collect and report standardized fraud data to FCAC

The data piece is particularly important.

It will give FCAC structured, comparable insights into how fraud is affecting Canadians. This includes what types of scams are occurring, how they unfold, and where protections are falling short.

The legal requirement for policies and procedures is equally important.

Currently, it is fair to say that every institution manages fraud and allegations of fraud somewhat differently.

As many in this audience appreciate, a requirement for effective policies and procedures has distinct benefits and consequences. It shifts compliance from a narrow, rules based exercise to a governance and controls based exercise embedded in an institution’s operating model.

By definition, it scales with risk and complexity, engages board oversight and is subject to systemic rather than episodic enforcement.

As I discussed earlier, these measures strengthen consumer protections that FCAC would be responsible for supervising.

This is an excellent first step, but it is also part of a broader, system-wide agenda.

Looking ahead, the government is exploring additional actions across sectors— including digital and telecommunications platforms—building on industry initiatives like the Canadian Anti-Scam Coalition.

And, as you may be aware, the federal government is also establishing a new Financial Crimes Agency to bring together expertise across law enforcement and intelligence.

This will help strengthen Canada’s ability to investigate serious and complex financial crimes, contribute to the recovery of illicit proceeds, and participate in international efforts to counter crimes of a financial nature.

And importantly, there is growing recognition of economic abuse as a form of financial harm and potential fraud.

A new Code of Conduct for the Prevention of Economic Abuse, to be overseen by FCAC, will set expectations for how financial institutions identify, prevent, mitigate, and respond to cases where individuals are experiencing, or are at risk of experiencing, economic abuse.

Taken together, these measures signal a clear direction: toward stronger protections, better data, and a more systems based approach.

Shared outcomes: What we should build toward

Let me return to the final point: shared outcomes.

Financial crime and fraud are not a single-institution problem—and it won’t be solved by single-institution solutions.

Rather, as I have attempted to convey, it is a shared problem, requiring shared solutions. But let’s now add the need for solutions to be focused on shared outcomes for consumers—the primary victims of fraud.

From a financial consumer perspective, let me leave you with a few success factors for establishing shared outcomes.

Before I speak to these, I would ask you to set aside, just for a moment, your job title, set aside the institutional lens you bring to this discussion, set aside how you meet this issue in your professional lives.

Instead, relate to the word consumer, not as an abstract category, but as someone in your own life who you care about.

This could be:

• your aging parent, hesitating before answering a text message
• a teenage son, daughter, niece, or nephew finding their way through social media that is littered with opportunities to get rich quick
• or a young adult quietly and carefully setting money aside in the savings account in the hopes of someday buying a first home

I ask you to see and think of these people in the word “consumers” as I lay out four simple success factors.

First, consumer awareness must remain essential, but not primary.

We should absolutely invest in education. But we cannot place the burden of protection on consumers alone. Success means a consumer—your parent, child, relative, or friend—can recognize risk, but they are not left carrying the full burden of prevention, response, or recovery when fraud occurs.

Awareness must be backed by safeguards, enforceable protections, and clear recourse.

In practice, that means a consumer knows where to turn, receives timely support, and is not left navigating a maze of institutions simply to understand who is responsible.

This brings me to my second success factor: the need for a clear and consistent baseline of protections.

When protections vary, gaps emerge, and those gaps will be exploited.

And when that happens, it is consumers who experience unfair treatment and negative financial outcomes.

Consistency matters here. It reduces complexity, it strengthens consumer trust and confidence in institutions, and it reinforces the resilience of the financial system as a whole.

Put simply, every consumer should be able to rely on a core set of protections, no matter how or where they engage with the financial marketplace.

Third, we need stronger information sharing.

In a multi-sector system, data and insight must move together. Success means regulators and institutions can see emerging patterns earlier, identify where harm is occurring, and act before isolated incidents become broader losses.

Who shares what, with whom, and for what purpose must be clear. Our delays and fragmentation will undermine our ability to prevent, detect, and respond.

When that clarity exists, institutions are not working at cross-purposes, and consumers are better protected because the system is able to intervene sooner.

Fourth, and finally, we need stronger coordination. And consumers need a true “no wrong door” experience.

Consumers should not be passed from institution to institution, and industry should not face conflicting expectations.

So, success here means a consumer can enter the system through any door and still receive a response that is timely, coherent, and focused on resolving harm rather than redirecting responsibility.

Because ultimately, fragmentation is not neutral. It is a vulnerability.

And one that fraudsters are all too ready to exploit, often at the expense of the very consumer you are thinking about.

Closing

Let me end where I started—with my sporting metaphor and the FIFA World Cup.

I may not be able to predict who will win the 2026 World Cup. But I can tell you what the winning team will almost certainly demonstrate:

Players who do not simply know their roles, but can read the field, respond to threats quickly and collectively, and support one another when the game shifts, because that is how the team actually achieves its goal.

Combating fraud demands an approach that can detect risks early, close gaps quickly, and adapt in real time to achieve the goal of protecting financial consumers and the financial system.

That is the essence of a systems-thinking approach to combat fraud.

FCAC looks forward to continuing to do its part.

We look forward to helping ensure the system works for consumers through strong supervision—by protecting their rights, raising public awareness, and enabling consumer trust in the financial system.

With that, I would like to thank you for your time today.

Thank you for the work you do to protect the integrity of Canada’s financial system and the financial well-being of Canadians.

And once again, thank you to the Canadian Institute for the invitation and for the privilege to speak to the connection between consumer protection and the broader fight against financial crime and fraud.