On June 3, 2025, the Government of Canada introduced Bill C-2, entitled the Strong Borders Act, in the House of Commons. Bill C-2 is a comprehensive border protection bill aimed at modernizing and strengthening national security measures, border enforcement, immigration controls, and financial oversight.

The Bill is designed to give law enforcement agencies and government departments expanded tools to combat organized crime, disrupt the flow of illegal drugs such as fentanyl, improve the integrity of the immigration system, and crack down on money laundering and illicit financing. To achieve this, Bill C-2 proposes sweeping reforms through amendments to 14 pieces of legislation, and introduces a new act, the Supporting Authorized Access to Information Act (SAAIA).

Border security and immigration

Bill C-2 proposes several legislative amendments to strengthen national security, improve immigration processes, and enhance Canada’s maritime and border integrity.

First, the Bill proposes amendments to the Oceans Act to expand Canadian Coast Guard services relating to security activities. These activities are intended to strengthen Canada's sovereignty and maritime domain awareness, particularly in remote Arctic waters. With these changes, the Canadian Coast Guard would be authorized to conduct security patrols and to collect, analyze, and share information and intelligence for security purposes.

The Bill also proposes to amend the Sex Offender Information Registration Act to enhance the ability of the Royal Canadian Mounted Police (RCMP) to share information on registered sex offenders. This includes sharing data collected under the Act with both domestic and international partners, including authorities in the United States.

Amendments are proposed to the Immigration and Refugee Protection Act and the Department of Citizenship and Immigration Act. These changes would authorize Immigration, Refugees and Citizenship Canada (IRCC) to share client informationsuch as identity, status, and immigration documentation with federal, provincial, and territorial partnersthrough formal information-sharing agreements. Additionally, the proposed amendments would make it easier for IRCC to share information internally across its various programs.

Further amendments to the Immigration and Refugee Protection Act would provide the federal government with greater control over immigration documents in the public interest. These new authorities, which could be used in response to public health concerns or national security threats, would enable the government to immediately cancel, suspend, or modify groups of immigration documents; to pause the acceptance of new applications; and to pause or cancel the processing of applications already in progress.

The Bill also seeks to improve and modernize the asylum system through additional amendments to the Immigration and Refugee Protection Act. These changes aim to make the system more efficient and accessible for claimants. Specifically, the amendments would simplify the online application process and create a unified process for asylum claims, whether made at a port of entry or at an inland IRCC office. Completed claims would be referred to the Immigration and Refugee Board of Canada (IRB) to expedite decisions.

In addition to these measures, the Bill proposes two new ineligibility provisions to protect the asylum system from sudden surges in claims:

  • Asylum claims made by individuals who have been in Canada for more than one year after June 24, 2020, without previously filing a claim, would not be referred to the IRB. This measure would apply to all individuals, including international students and temporary residents, regardless of whether they have left and returned to the country.
  • Those who enter Canada from the United States at points between official border crossings and submit an asylum claim more than 14 days after entry would be rendered ineligible.

However, individuals affected by these ineligibility provisions may still apply for a pre-removal risk assessment (PRRA) to ensure they are not returned to a country where they may face harm.

Organized crime and drug trafficking

To combat the growing threat of transnational organized crime and the illegal fentanyl trade, the Bill proposes to amend the Controlled Drugs and Substances Act to create a new accelerated scheduling pathway. This pathway would allow the Minister of Health to rapidly control precursor chemicals that can be used to produce illicit drugs. The goal is to enable law enforcement and border agencies to take swift action to prevent the illegal importation and use of these chemicals, while ensuring oversight over their legitimate use.

Bill C-2 seeks to amend the Criminal Code, the Customs Act, the Mutual Legal Assistance in Criminal Matters Act, and the Canadian Security Intelligence Service (CSIS) Act to enhance law enforcement capabilities. These amendments aim to:

  • Facilitate law enforcement’s lawful access to information and data needed during the early stages of criminal investigations, and ensure that CSIS’s investigative tools keep pace with evolving threats.
  • Update existing law enforcement tools to address modern digital challenges, including providing clear legal authority for the search of computer systems and data stored on or accessible from those systems.
  • Clarify the circumstances under which law enforcement can exercise specific powers and seize information without a warrant in urgent, time-sensitive situations. The government uses the example of “live child abuse” as an example of such an urgent situation where warrantless access would be permitted.
  • Require transporters and warehouse operators to provide access to their premises for export inspections by Canada Border Services Agency (CBSA) officers. The Bill would also obligate owners and operators of certain ports of entry or exit to provide facilities for such inspections, similar to the requirements already in place for imported goods.

The Bill also introduces the Supporting Authorized Access to Information Act (SAAIA). This legislation would ensure that electronic service providers (ESPs) have the necessary capabilities to assist law enforcement agencies and CSIS in criminal and intelligence investigations. Specifically, it would require ESPs to comply with lawfully authorized requests to access or intercept information and communications.

Finally, the Bill proposes amendments to the Canada Post Corporation Act to remove existing barriers that prevent police from searching mail when authorized to do so under an Act of Parliament for the purposes of a criminal investigation. It would also expand Canada Post’s inspection authority to open mail.

Illicit financing and money laundering

The Bill targets financial crime by proposing extensive updates to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Key changes include:

  • Tougher enforcement and penalties for non-compliance with anti-money laundering laws, including:
    • Raising the maximum penalty amount for a single prescribed violation under the PCMLTFA from $100,000 to $4,000,000 for individuals and from $500,000 to $20,000,000 for entities.
    • Imposing a cumulative maximum penalty for all prescribed violations: the greater of $4 million or 3% of global income for individuals, and the greater of $20 million or 3% of global revenue for entities, based on the financial year preceding the year the penalty is imposed.
      • FINTRAC will take into account capacity to pay in determining the amount of a penalty
    • Requiring all notices of violation issued by FINTRAC to be accompanied by a compliance order, which is currently optional.
  • Restrictions on high-risk financial activities:
    • Prohibiting businesses or persons engaged in a profession or the solicitation of charitable financial donations from the public from accepting cash payments, donations or deposits of $10,000 or more.
      • Note: there are exceptions to this for certain deposit-taking institutions and entities or classes of transactions that may be carved out by regulations yet to be released.
    • Prohibiting certain deposit-taking institutions from accepting cash deposits to an account from a third-party depositor who is not the account holder or authorized to give instructions on that account.
  • Mandatory enrolment with FINTRAC for all FINTRAC reporting entities not already required to register. This includes those recently brought into scope of FINTRAC reporting, such as factoring companies, cheque cashing businesses and financing and leasing companies.
  • Expanded information sharing between FINTRAC and the Office of the Commissioner of Canada Elections.
  • Clarified rules to support public-private collaboration against money laundering, and integration with the Integrated Money Laundering Intelligence Partnership (IMLIP).
  • Amendments to the PCMLTFA authorizing reporting entities to collect and use personal information without an individual’s knowledge or consent when it is disclosed by law enforcement for the purposes of detecting or deterring money laundering, terrorist financing, or sanctions evasion, with protections for good faith use. Corresponding changes to PIPEDA clarifying that such collection and use is permissible under privacy law when done in accordance with the new PCMLTFA provisions.

Additionally, the Bill seeks to make the Director of FINTRAC a member of the Financial Institutions Supervisory Committee (FISC), enhancing oversight and collaboration across Canada's financial sector.

Next steps

Bill C-2 is now being debated at second reading in the House of Commons. The governing Liberals have expressed their desire for the bill to move through the legislative process quickly as Parliament is expected to rise on June 20, 2025, for summer recess.

In this minority Parliament, the government will require the support of at least one opposition party to pass Bill C-2 through the House expeditiously. Some opposition MPs have expressed concerns about the scope of the Bill and the potential for government overreach, especially regarding privacy and warrantless searches. Concerns outlined at this early point in the legislative process may lead to calls for an intensive study of the Bill at committee stage.

For more information about Bill C-2, please contact a member of our team.