Bill C-2 Security vs Freedom

Bill C-2 Revised Cartoon
Read Full Bill Text Here

An Act Respecting Certain Measures Relating to the Security of the Border Between Canada and the United States and Respecting Other Related Security Measures.

Short Title: Strong Borders Act 

Bill Type:  House Government Bill 

Bill Sponsor:  Minister of Public Safety

Status: 2nd Reading — September 17, 2025. This Bill has not passed yet.

Estimated Read Time: 3 minutes

⚠️ Parts of Bill C‑2 were later reintroduced through other Bills. Many immigration, border and anti-money laundering measures were carried into Bill C‑12, which received Royal Assent on March 26, 2026. The lawful-access and communications-data measures were later reintroduced through Bill C‑22. Bill C‑2 remains at 2nd Reading.

What is this Bill For?

  • Bill C‑2 — Strong Borders Act is a broad border and security Bill covering customs, illegal drugs, mail, immigration, financial crime, digital information and other security measures. This page focuses on its anti-money laundering, cash transaction and communications-data provisions:
  • creates new registration requirements for money services businesses
  • bans large cash transactions 
  • expands law enforcement access to financial and communications data
  • introduces penalties up to $30 million per violation

WHO GAINS POWER

  • Law enforcement gains expanded authority to seek financial data, communications records and information held by telecom and internet companies. Some access requires a warrant, production order or other legal authority while other demands use lower legal thresholds.
  • Financial regulators gain a new compliance order system. An entity that violates a compliance order can face a penalty of up to the greater of $30 million or 3% of its gross global revenue.
  • Government agencies gain new information-sharing powers between departments for financial crime investigations — data that previously stayed within individual agencies can now move across the system

WHO LOSES POWER

  • Individuals face new limits on using cash for business transactions of $10,000 or more, subject to exemptions set by Regulation. Financial entities cannot accept a cash deposit from someone who is not the account holder or authorized to give instructions on the account.
  • Businesses lose operational flexibility — any money services business or foreign exchange dealer not registered under the new regime faces penalties and potential shutdown
  • Privacy protections lose ground. The Supporting Authorized Access to Information Act requires telecoms and internet companies to assist law enforcement in accessing data — expanding the surveillance architecture beyond financial transactions into communications

WHO GAINS MONEY

  • Government collects penalties — up to $20 million per entity and $4 million per individual for registration violations and up to $30 million for compliance order breaches
  • The compliance industry — lawyers, consultants and software providers — gains new business from every business that needs help meeting the new requirements
  • Large financial institutions absorb compliance costs more easily than small competitors, consolidating market share as smaller money services businesses exit

WHO LOSES MONEY

  • Small money services businesses and foreign exchange dealers face the highest relative compliance burden — registration, reporting, record-keeping and penalty exposure that large institutions can absorb but small operators cannot
  • Consumers pay higher fees as financial institutions pass compliance costs down the chain
  • Anyone caught in violation faces penalties that can reach $30 million — a number calibrated to punish large operators but capable of destroying smaller ones

THE CATCH

Bill C-2 trades financial privacy and cash freedom for expanded Government surveillance and enforcement power. The stated goal is stopping money laundering and terrorist financing. The mechanism is:

  • Banning cash transactions over $10,000
  • Requiring businesses to register and report
  • Giving law enforcement broader data access
  • Requiring telecoms to assist surveillance
  • Imposing penalties large enough to force compliance

Whether those tools stop financial crime — or primarily burden legitimate small businesses while sophisticated criminal networks adapt — depends entirely on how the regulations are written and applied.

The compliance and penalty system is not accountable to:

  • An independent tribunal — compliance orders are issued by regulators, not adjudicated by an independent body before they take effect
  • Parliament — information sharing between agencies operates under Ministerial authority, not Parliamentary oversight
  • Privacy Commissioner (proactively) — the Supporting Authorized Access to Information Act expands telecom assistance obligations without a mandatory privacy impact assessment built into the statute
  • Small business — no exemption or scaled penalty structure for operators below a certain size

⚠️ No Independent Adjudication — Compliance orders carry penalties up to $30 million and take effect before any independent tribunal reviews them. The regulator investigates, charges and penalizes — with no mandatory independent check before enforcement begins.

⚠️ Surveillance Without Privacy Assessment — The Supporting Authorized Access to Information Act requires telecoms and internet companies to assist law enforcement in accessing data. No mandatory privacy impact assessment is built into the statute.