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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, Sponsor Minister of Public Safety
Status: Debate at second reading on Wednesday, September 17, 2025
(House of Commons)
Bill C-2: Strong Borders Act - Power & Money Analysis
Bill C-2 strengthens Canada's anti-money laundering and terrorist financing laws. It creates new registration requirements for money services businesses, bans large cash transactions, expands law enforcement access to financial and communications data, and introduces penalties up to $30 million per violation. A companion piece — the Supporting Authorized Access to Information Act — requires telecom and internet companies to help law enforcement access data on request.
WHO GAINS POWER
Law enforcement gains expanded authority to access financial data, communications records and information held by telecom and internet companies — without the current limitations on surveillance.
Financial regulators gain a new "compliance order" system with penalty authority up to $30 million per violation — higher than any existing financial penalty in Canadian law.
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 lose the freedom to use cash for transactions over $10,000. Third-party cash deposits into accounts are banned outright.
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 CORE TRADE-OFF
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 how enforcement is prioritized.
WHO HOLDS THE SYSTEM ACCOUNTABLE?
The compliance order system and penalty regime are NOT accountable to:
- ❌ 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
[Source: Bill C-2 — Strong Borders Act, Second Reading, September 17, 2025]