The Canadian federal government introduced Bill C‑2, also known as the Strong Borders Act, in June 2025. While the bill is currently at its first reading in the House of Commons, it sends a clear signal: the government intends to significantly strengthen Canada’s approach to anti-money laundering (AML) enforcement—especially for Money Services Businesses (MSBs) and fintechs.

Although this legislation is not yet law, it’s already shaping the compliance conversation. For MSBs operating in Canada, now is the time to prepare, not react.

👉 View the full text and status of Bill C‑2 on the Parliament of Canada website.


What Does Bill C‑2 Propose?

If passed, Bill C‑2 would introduce wide-reaching amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Highlights include:

  • Expanding FINTRAC registration mandatory for all MSBs previously only requiring enrollment
  • Introducing criminal penalties for operating without registration
  • Prohibiting cash transactions over $10,000 for most businesses and charities (with limited exemptions)
  • Significantly increasing penalties for non-compliance, by as much as 40×
  • Expanding FINTRAC’s enforcement and data-sharing powers

While these measures are not yet enacted, they clearly outline the federal government’s regulatory direction.


Why It Matters Now

Even at first reading, Bill C‑2 reflects a policy shift already underway: Canada is tightening its AML framework and aligning more closely with international standards, including the U.S. FinCEN model.

For MSBs and related businesses, this means:

  • Higher scrutiny on registration and reporting
  • Reduced tolerance for informal or undocumented compliance practices
  • Greater risk of enforcement actions—even under current law

Businesses that begin aligning with the bill’s principles today will be better prepared if (or when) these proposals become law.


How to Stay Ahead

Nancy works with MSBs, fintechs, and charities across Canada to:

  • Determine whether FINTRAC registration is already required
  • Build or refine AML compliance programs
  • Prepare for FINTRAC audits and inspections
  • Reduce regulatory risk through legal clarity and documentation

Taking action early protects your business—and your reputation.
Even if Bill C‑2 changes, the enforcement climate is already shifting.


🛑 Disclaimer

As of publication, Bill C‑2 is at first reading in the House of Commons and has not been enacted. This article is for general informational purposes only and does not constitute legal advice.


Coming Next

➡️ How to Register as an MSB in Canada – 2025 Guide
➡️ Avoiding FINTRAC Fines: Enforcement Risks and Readiness
➡️ Cross-Border Compliance for MSBs: Canada and the U.S.

Nancy Walker

Welcome to Walker Guidance! Your trusted resource for expert advice on compliance and legal matters tailored to Fintech companies, MSBs, and payment service providers. Here, we break down complex regulatory requirements, contracts, and governance strategies into actionable solutions to help your business thrive. Let’s work together to ensure you stay compliant, build trust, and drive sustainable growth in a rapidly evolving landscape.