Law360 Canada (October 8, 2025, 2:41 PM EDT) — In part one of this series (see below for link), we traced the broad ambitions of Bill C-2, the so-called Strong Borders Act. We examined how Canada, under mounting domestic and international pressure, sought to overhaul its anti-money laundering (AML) and counter-terrorist financing (CTF) framework, repositioning itself against increasingly sophisticated networks of financial crime (Government of Canada, 2025; FATF, 2022). That first instalment highlighted the bill’s sweeping recalibration of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), its elevation of FINTRAC into a far more muscular regulator, and its attempt to harden Canada’s borders against precursor chemicals, illicit funds and contraband.

In part two, we shifted gears. There, we scrutinized the criticisms. From privacy advocates alarmed at expanded surveillance, to charities and small businesses anxious over draconian fines, to constitutional lawyers warning of potential erosion of solicitor-client privilege, the concerns were substantial and could not be dismissed as mere teething pains (Geist, 2025; Citizen Lab, 2025; Canadian Centre for Christian Charities, 2025). That analysis made clear that Bill C-2 is not a simple victory for national security; it is a balancing act — bold, yes, but fraught with the risk of overreach.

Now, in part three, we turn to the most pressing question of all: what happens next? How should Canada implement the Act in practice? What safeguards must be built in to preserve democratic legitimacy? And how can the country ensure this ambitious reform delivers tangible results without sacrificing the liberties that underpin its legal order?

Building a smarter AML regime

Canada’s AML framework has historically been criticized as both under-enforced and over-complicated — strong on paper, weak in practice (Cullen Commission, 2022). Bill C-2 risks repeating this pattern unless its implementation shifts away from mere rule proliferation toward smarter enforcement.

Here, RegTech (regulatory technology) and SupTech (supervisory technology) offer real promise. Artificial intelligence and machine learning can parse enormous datasets, detecting suspicious anomalies far beyond human capacity (OECD, 2024). If deployed responsibly, these tools can filter noise from signal, reducing compliance burdens on low-risk actors while sharpening focus on high-risk sectors such as real estate, private investment funds and digital assets.

Let’s not get carried away and fool ourselves — technology alone is insufficient. Regulators must embed risk-based approaches, consistent with global standards set by the Financial Action Task Force (FATF, 2022). This means tailoring compliance expectations to institutional size and exposure, thereby avoiding the trap of overburdening credit unions, charities and small firms with the same obligations as multinational banks.

Enhancing oversight and accountability Expanding FINTRAC’s powers, as Bill C-2 does, without a corresponding boost in oversight is a recipe for public mistrust. Both privacy law scholars and civil society groups have warned of the dangers of unchecked data collection (Geist, 2025; OpenMedia, 2025).

Canada would do well to emulate models from our neighbours; so why reinvent the wheel? The United Kingdom has an Independent Reviewer of Terrorism Legislation, charged with scrutinizing counter-terror and AML powers, issuing regular reports that are publicly debated (U.K. Home Office, 2021). In the United States, congressional oversight committees actively monitor Treasury enforcement under the Bank Secrecy Act.

So, let me think out loud for a moment. A Canadian equivalent — perhaps a Parliamentary Officer for Financial Surveillance and Integrity — could provide that missing accountability. An annual, public-facing report, coupled with the power to audit FINTRAC’s use of its new authorities, would reinforce the message that Canada values transparency as much as enforcement.

Strengthening international cooperation

Illicit finance flows across borders with ease. Money launderers exploit weak links, whether that be opaque shell companies in Delaware, under-regulated real estate markets in London or Vancouver, or crypto exchanges in offshore jurisdictions. I am going to be bold and say that Bill C-2 can only succeed if Canada doubles down on international cooperation.

That means deepening engagement with the Financial Action Task Force (FATF, 2023), the Egmont Group of Financial Intelligence Units, and entering reciprocal information-sharing agreements with allies, particularly the United States and European Union. Crucially, cooperation must be two-way. Canadian institutions should not become net exporters of intelligence without receiving actionable data in return.

Balancing security and liberty

The most delicate challenge ahead lies in balancing security with civil liberties. Critics rightly warn that over-criminalization and creeping surveillance could disproportionately impact immigrant and minority communities, many of whom already face barriers to banking (Canadian Civil Liberties Association, 2025).

Bill C-2’s future legitimacy depends on embedding sunset clauses, periodic reviews and public consultations into its implementation. These mechanisms would ensure AML measures remain subject to democratic recalibration. The Supreme Court of Canada’s ruling in Charkaoui v. Canada (Citizenship and Immigration), 2007 SCC 9 serves as a reminder that even in matters of national security, the Charter cannot be sidelined. Liberty and security, properly understood, reinforce one another rather than stand in opposition.

Toward a culture of compliance

Finally, Canada must foster not only compliance, but a culture of compliance. Financial institutions, accountants, real estate professionals and lawyers alike must move beyond viewing AML duties as bureaucratic burdens. Instead, they should see themselves as stakeholders in safeguarding Canada’s financial system.

This requires training, dialogue and partnership between regulators and the private sector. Compliance fatigue is real and heavy-handed enforcement risks alienating those whose cooperation is essential. Trust and collaboration, not only fines and penalties, must define the next chapter.

A turning point, not the destination

Bill C-2 may well be remembered as a defining moment in Canada’s AML history. No doubt — it is bold, far-reaching and ambitious. But it is not the destination. Its ultimate success will hinge not on its text but on its implementation: whether technology is harnessed wisely, whether oversight is strengthened, whether cooperation is deepened and whether rights are preserved.

I will part with saying this.

Bill C-2 is both bold and flawed. It reflects a determined effort to fortify national defences against financial crime, but it must survive legal scrutiny, operational reality and democratic accountability. The next chapter of Canada’s AML journey will not be written in Parliament alone — it will be written in courts, in boardrooms, in charities and in the lives of everyday Canadians whose trust in the financial system must be protected.

Part one showed the law is sweeping. Part two reminded us that its risks are real. Part three now argues that the future lies in careful stewardship — ensuring that Canada’s bid to cleanse its financial system does not become an experiment in overreach, but a model of how democracies can protect themselves without losing their soul.

The series ends here, but the national conversation on Bill C-2 is only beginning.

This is the final part of a three-part series. Part one: The Strong Borders Act and a shifting anti- money laundering landscape; part two: The gathering storm of the Strong Borders Act: Criticisms of Bill C-2.

Hodine Williams has over 20 years of experience in law, corporate governance and regulatory compliance across the legal, financial, hospitality and engineering sectors. A former prosecutor and expert in digital forensics, financial crimes and cyber law, he has advised corporations in Jamaica, Canada and the United Kingdom. Holding a master of laws in international business law from Osgoode Hall Law School, along with degrees in management and economics and law, Williams is also an educator, philanthropist and advocate for youth development and racialized communities. You can reach him at hodine.williams@gmail.com.

The opinions expressed are those of the author(s) and do not necessarily reflect the views of the author’s firm, its clients, Law360 Canada, LexisNexis Canada or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.

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