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ARTICLE · 06 JUNE 2025

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Strong Borders Act: A Landmark Shift In Canada's AML Penalties

Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
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Blake, Cassels & Graydon LLP

Blake, Cassels & Graydon LLP

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On June 3, 2025, Canada's new federal government introduced Bill C-2 (Bill), the Strong Borders Act, for first reading in the House of Commons.

CanadaFinance and Banking
Jacqueline Shinfield
Jacqueline Shinfield
Vladimir Shatiryan
Vladimir Shatiryan
Ora Morison
Ora Morison
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On June 3, 2025, Canada's new federal government introduced Bill C-2 (Bill), the Strong Borders Act, for first reading in the House of Commons. The Bill includes significant amendments to Canada's anti-money laundering legislation and introduces a new administrative monetary penalty (AMP) framework that is unprecedented in the Canadian financial services sector for the severity of its penalties. If enacted, the new penalty framework could transform how financial institutions and other reporting entities approach enforcement exposure under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

The Bill will also require all reporting entities under the PCMLTFA to enrol with the Financial Transactions and Reports Analysis Centre (FINTRAC) and to renew their enrolment periodically. In addition, the Bill will enact a comprehensive ban on the acceptance of cash payments of C$10,000 or more by all businesses and charities in the Canadian economy,

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