On April 27, 2026, the Government of Canada introduced Bill C-29, the Financial Crimes Agency Act, for first reading in the House of Commons. The legislation delivers on a key commitment from Budget 2025 and forms one pillar of a broader new approach to financial crime, including the new National Anti-Fraud Strategy currently being developed by Finance Canada.

The road to Bill C-29

Recent federal initiatives have advanced towards a more robust and connected financial crime enforcement framework. The Strengthening Canada’s Immigration System and Borders Act (Bill C-12), which received royal assent on March 26, 2026, marks a significant development in this regard.

Originally introduced as the Strong Borders Act (Bill C-2) in 2025, the legislation amends 14 statutes and includes substantial changes to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”). These amendments increased significantly the maximum administrative monetary penalties and criminal penalties under the PCMLTFA and added new tools and information sharing authority for its administrator, the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”).

In parallel, the federal government has taken steps to strengthen operational coordination. The Integrated Money Laundering Intelligence Partnership (“IMLIP”), launched in 2025, provides a forum for information sharing between law enforcement and major financial institutions without changing existing privacy or reporting obligations as it relates to money laundering and organized crime intelligence.

These developments, together with the proposed Financial Crimes Agency, point to a more coordinated enforcement environment. Notably, this partnership is not designed to obfuscate privacy laws as it relates to the disclosure of personal information. Rather, it is a direct response to the Canada-US Joint Strike Force to combat organized crime, fentanyl trafficking, and money laundering.

Budget 2025 also announced a National Anti-Fraud Strategy in response to reported fraud losses exceeding $704 million in 2025. A Department of Finance consultation paper released on April 14, 2026 outlined proposed measures, including new cross-sector market conduct requirements, enhanced public awareness, and targeted information-sharing to support law enforcement. The consultation period closed on April 28, 2026.

The proposed Financial Crimes Agency Act

Bill C-29 is focused on standing up the Financial Crimes Agency ("FCA") as a specialized federal law enforcement agency. The key features it proposes are as follows:

  • Mandate: The FCA's statutory mandate is to investigate financial crimes and contribute to the recovery of proceeds of crime. The stated object of the Act is to create a new federal agency with the capability and expertise necessary to investigate serious and complex financial crimes, contribute to the recovery of proceeds of crime, and participate in international efforts to counter crimes of a financial nature.
  • Definition of "financial crime": The Act defines "financial crime" broadly as:
    1. Any offence under a federal act relating to financial assets—including digital assets—involving laundering, trafficking or possession of proceeds of crime, or any conduct that does or has the potential to adversely affect the security or integrity of Canada’s economy or financial system or of any financial market in Canada.
    2. Designated offences under the Criminal Code from which proceeds of crime are derived.
    3. Offences under the PCMLTFA.
  • Focus on “serious and complex financial crimes”: The Act contemplates providing additional precision as to the types of matters that will be investigated with the Commissioner being given the power to establish criteria respecting which matters should be investigated under the Act. This power is permissive as opposed to mandatory, but may provide additional guidance.
  • Governance and structure: The Minister of Finance is responsible for the FCA. It will be led by a Commissioner appointed by the Governor in Council for a term of up to five years, renewable up to a maximum of ten years total. The Commissioner holds the rank and powers of a deputy head of a department and is a peace officer throughout Canada. The Minister may issue directions to the Commissioner on matters of public policy or strategic direction, which must be made public.
  • Investigative powers: The Commissioner may investigate any financial crime or any offence under an Act of Parliament committed in relation to a financial crime. Investigations may be commenced on the Commissioner's own initiative or at the request of, or in collaboration with, any law enforcement agency or public body in or outside Canada. The Commissioner may designate employees as "investigations officers" (who are public officers for the purposes of the Criminal Code) or as "police officers" (who become peace officers throughout Canada).
  • Role of the Attorney General of Canada: Despite any other Act of Parliament, the Attorney General of Canada may conduct proceedings in respect of a financial crime investigated under the Act. This does not displace provincial Attorneys General, except where the federal Attorney General issues a fiat, which can be based on factors including whether the offence is transnational, committed in more than one province, or involves the national interest.
  • Arrangement with the RCMP: The Commissioner and the Commissioner of the RCMP must enter into an arrangement for the RCMP to provide services and assistance to the FCA.This acknowledges that the FCA will need to draw on existing policing resources as it stands up operations.
  • Agreements and information sharing: The FCA may enter into contracts, agreements, or other arrangements with any person or entity, including for information sharing in relation to financial crimes or collaborating in investigations.
  • Accountability mechanisms: The Commissioner must submit an annual report to the Minister of Finance beginning after the FCA’s first full year of operations, which must be tabled in Parliament. The Act is subject to a mandatory five-year review. The Act also amends the Public Complaints and Review Commission Act to enable individuals to make complaints about the conduct of FCA employees designated as police officers.
  • Consequential amendments: Bill C-29 makes numerous consequential amendments, adding the FCA to provisions under the Access to Information Act, Privacy Act, Financial Administration Act, Public Service Superannuation Act, Criminal Code, Special Economic Measures Act, Immigration and Refugee Protection Act, Security of Canada Information Disclosure Act, and the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), among others.

Key considerations

The introduction of Bill C-29 raises several considerations for organizations operating in the financial sector.

A new enforcement actor in a tougher penalty environment

The FCA will be a dedicated, resourced federal law enforcement body focused exclusively on financial crime. Unlike the current fragmented landscape, where the RCMP, provincial police, and other bodies have overlapping mandates, the FCA is designed to concentrate expertise and capability.

Critically, the FCA will operate in a heightened criminal liability environment, like the new PCMLTFA penalty regime introduced under Bill C-12. For financial sector participants, this means a more coordinated and potentially more aggressive investigative counterpart, backed by dramatically enhanced penalty provisions.

Expanded information sharing

The consequential amendments bring the FCA into a range of information-sharing regimes. The Special Economic Measures Act and Justice for Victims of Corrupt Foreign Officials Act amendments add the FCA Commissioner to the list of officials who may share information with the Minister of Finance. The Immigration and Refugee Protection Act amendments permit sharing of biometric information with the FCA. Citizenship regulations will allow disclosure of identity and status information to the FCA.

These Bill C-29 provisions build directly on the information-sharing expansions already enacted in Bill C-12, which broadened IRCC's authority to share personal information with federal and provincial partners and authorized FINTRAC to share information with the Commissioner of Canada Elections. They also complement the operational intelligence-sharing channels established through IMLIP, which signals the government's expectation that major financial institutions will engage proactively and collaboratively with law enforcement on money laundering and organized crime threats.

Over time, financial services organizations should expect broader requests for information and should review their data governance frameworks accordingly.

Digital assets expressly in scope

The definition of "financial crime" explicitly includes offences relating to digital assets. This is a notable legislative choice. While provincial securities regulators, through the Canadian Securities Administrators (“CSA”), have developed an extensive regulatory framework for crypto asset trading platforms (“CTPs”) under existing securities legislation, including registration requirements, custody and segregation standards, restrictions on leverage, and detailed obligations in respect of Value-Referenced Crypto Assets (commonly referred to as stablecoins), the federal criminal enforcement apparatus has, until now, lacked a dedicated institutional mandate expressly covering digital assets.

Bill C-29’s inclusion of digital assets within the FCA’s mandate is also consistent with the federal government’s broader ambition to regulate the digital asset space at the national level: Budget 2025 introduced a dedicated federal Stablecoin Act, to be administered by the Bank of Canada, that would regulate the issuance of fiat-backed crypto assets in Canada and impose reserve, custody, and operational requirements on stablecoin issuers, with related amendments to the Retail Payment Activities Act capturing payment service providers that use prescribed stablecoins.

By bringing digital assets within the FCA’s statutory definition of “financial crime,” Bill C-29 thus creates a federal enforcement counterpart to both the existing provincial securities regulatory regime and this emerging federal prudential framework for stablecoins. Crypto-asset exchanges, digital payment providers, custodians, stablecoin issuers, and fintech operators should take note, as conduct involving digital assets that adversely affects the integrity of Canada’s financial system or markets could now attract dedicated federal criminal investigation under the FCA, in addition to existing regulatory oversight by provincial securities regulators and FINTRAC.

It is noteworthy that these provisions should, in theory, work in harmony with the special warrants now available under the Criminal Code to seize digital assets. However, this will require provincial and federal prosecutors to work with the Financial Crimes Agency, particularly if intelligence gathered through the new Agency is used to ground judicial authorizations.

In this respect, Bill C-29 directly permits the Commissioner to consult with any relevant law enforcement agency in Canada. This type of consultation, whether these new authorities under Bill C-29 will pass constitutional muster, should they be challenged, given the Supreme Court of Canada’s decision in R. v. Bykovets, which now requires law enforcement to obtain a warrant in order to obtain an IP address at a bare minimum.

Next steps

Bill C-29 will proceed through the Parliamentary process. Meanwhile, organizations in the financial services, telecommunications, and digital platform sectors should begin assessing their fraud governance arrangements, data-sharing capabilities, and internal dispute resolution processes against the obligations foreshadowed in the discussion paper. While many of these obligations remain at the proposal stage, the direction of travel is clear, and the legislative process is now in motion.

Bill C-29 addresses only one component of the National Anti-Fraud Strategy. Significant further legislative and regulatory action will be required to deliver the Strategy as described in the discussion paper. The centrepiece of the proposed strategy, a new framework with a central regulator imposing prevention, detection, disruption, and response obligations on federally regulated financial institutions, telecommunications service providers, and digital platforms, has not yet been released. This may involve new market-conduct legislation or significant amendments to existing statutes such as the Bank Act, the Telecommunications Act, and potentially new digital platform legislation.

To learn more or discuss how these changes could affect your business, please contact one of the authors or a member of our Financial Services Regulation or White Collar Defence & Investigations groups.