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: Debate at Second Reading on Wednesday, September 17, 2025
(House of Commons)
Bill C-2: Strong Borders Act
What is this Bill For?
Bill C-2 — Strong Borders Act strengthens Canada's anti-money laundering and terrorist financing laws:
- 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
Status: 2nd Reading — September 17, 2025. This Bill has not passed yet.
How would YOU vote? Scroll down to vote and comment below.
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 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.
[Source: Bill C-2 — Strong Borders Act, Second Reading, September 17, 2025]