Danny Santapaga, a self-employed financial adviser, bought 14 guns on 10 different occasions over seven months.

Plumber Graham Jovanovic purchased nine firearms over five weeks. University student Justin Green obtained 23 handguns during a 22-month period, including 15 from one store. Security guard Andrew Winchester acquired 47 handguns in a six-month buying binge.

These Toronto men have no apparent connection to one another. But they share a common thread.

Each used a valid firearms licence to buy multiple weapons at legitimate GTA-area stores and sold them to criminals, representing “a different kind of gun trafficking than we have encountered in the past,” Philip Enright, deputy director with the province’s guns and gangs unit, wrote in email.

Remarkably, there were no red flags, despite the fact that all the handguns, at the time of purchase, would have been added to the Canadian Firearms Registry.

A Toronto police memo prepared for city staff after this year’s spike in gun violence says serious “gaps” have turned domestic firearms trafficking into a “very real problem in Canada,” and puts some of the blame on the RCMP, the agency that administers the Canadian Firearms Program.

Not long ago, an estimated 70 per cent of guns used in Toronto crimes were smuggled from the United States, while 30 per cent were domestically sourced, the memo says.

Over the past couple of years that has shifted, with Toronto thugs now getting 50 per cent of their illicit guns in Canada, either stolen from legal owners or through “straw purchases,” when a licensed buyer sells a gun on the black market usually for an inflated price.

“Once they have... a licence they can buy as many guns as they want,” reads the five-page document dated July 22, 2016 and obtained by the Star. It was written by Supt. Gordon Sneddon of the Toronto Police Service’s Organized Crime Enforcement unit.

Toronto police Chief Mark Saunders acknowledged the changing trend in a recent meeting with the Toronto Star editorial board.

“Most of the firearms are coming from Canada, into bad guys’ hands. So, I think we’ve got some opportunities to fill those gaps,” he said.

Case summaries included in sentencing decisions indicate Toronto police only became aware that individuals were amassing small arsenals after they started seizing legally registered guns at crime scenes, including a Bond Arms Snake Slayer IV handgun purchased by Green and used in an armed robbery outside Fairview Mall on Jan. 20, 2014.

“The police run the serial number and it comes back to the registered owner,” Enright wrote in an email. “The registered owner never reported the gun missing or stolen (as is required under the law). Natural inference: gun owner never reported the handgun stolen because he sold it illegally.”

The four men were convicted separately of firearms trafficking within the last few years and are now serving prison sentences. Green and Winchester “saw the business opportunity,” the memo says. Santapaga and Jovanovic sold guns to finance drugs that had taken over their lives, court records indicate.

Similar cases are still before the courts in Toronto and other parts of Canada.

The memo suggests internal conflict within the RCMP has created obstacles to police obtaining information from the firearm registry.

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“The regulatory side and the investigative side although administered by the same organization i.e. the RCMP are frequently in conflict,” the memo says.

“Often that manifests itself in an inability or reluctance to share information with each other, Provincial and Municipal Agencies. This is in my view usually based on (a) lack of understanding and a failure to recognize one of their primary purposes is public safety,” the memo says. “As an example of that there was a time and still is to a degree where they felt they couldn’t share licensing information with their own analysts.”

While more could be done to prevent domestic firearms trafficking, the memo says it hasn’t happened because of “the conflict between the two sides of the Canadian Firearms Program.”

The RCMP did not respond directly to a request for comment about the contents of the Toronto police memo or why no concerns were raised about firearm licence holders making multiple purchases.

“Information about firearms licensing and registration is available to law enforcement officers through the Canadian Firearms Registry Online, which is accessed through the Canadian Police Information Centre database,” said an email from RCMP Staff-Sgt. Harold Pfleiderer.

According to the police memo sent to city hall, some of the fault lies in the firearm licensing process, which has a “mindset” that only law-abiding people apply for a licence.

“No one is thinking ‘dirty’ during the review process. Only in extremely rare cases is there ever a personal interview or visit by the (Chief Firearms Officer) or staff in Ontario. Telephone Detective would be a good description of the current process,” the memo states.

In Ontario, firearms licensing is the responsibility of the Chief Firearms Officer — an Ontario Provincial Police employee appointed by the province. The OPP didn’t immediately respond to a request for comment.

The Toronto police memo also says that since the long-gun registry was abolished by the federal Conservatives in 2012, there is increasing use of shotguns and rifles by the criminal element.

“It’s ironic that in the U.S.A. every sale of a gun including long guns can be traced by the ATF (Bureau of Alcohol, Tobacco, Firearms and Explosives) as the store owner is required to report the sale to the ATF,” it says.

“In Canada we do neither.”