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.