Exempt MSBs from Bill C-2 cash limit
Petitioners ask to amend Bill C-2 to exempt FINTRAC-registered MSBs from the $10,000 cash-acceptance restriction in s.77.5(3)(a). The government responds that it will not grant a blanket MSB exemption and will consult on implementation.
Why we would sign this petition
- Allows FINTRAC-registered, compliant MSBs to continue accepting large cash payments, avoiding operational disruption and preserving lawful services for customers.
- Maintains competition and financial inclusion by preserving remittances, currency exchange and other services MSBs provide.
- Aligns Bill C-2 with existing federal AML/ATF oversight by recognizing registered MSBs subject to the Proceeds of Crime (ML) and Terrorist Financing Act.
Why we wouldn’t sign this petition
- MSBs have higher vulnerability to cash-based money laundering and terrorist financing, so exempting them could increase illicit finance risks.
- The cash restriction targets common laundering channels; exempting MSBs could create a loophole and reduce the measure’s effectiveness.
- The government argues deposit-taking institutions better channel cash into the regulated system; targeted mitigations and consultations may be safer than a blanket exemption.
The summary and both sets of reasons are AI-generated from the petition and given equal weight. Claims are the petitioners’ own; consult the official record for the full text.
Official petition
PETITION TO THE HOUSE OF COMMONS OF CANADA IN PARLIAMENT ASSEMBLED WHEREAS: • Money Services Businesses (MSBs) operating in Canada are federally regulated entities subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations; • Such MSBs are required to register with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and to comply with prescribed anti-money laundering and anti-terrorist financing obligations, including reporting, record-keeping, and client identification requirements; • Bill C-2, the Strong Borders Act, proposes, under section 77.5(3)(a), restrictions on the acceptance of cash payments of $10,000 or more, while providing exemptions for certain regulated entities; • Bill C-2 does not provide a corresponding exemption for federally registered and compliant MSBs; The absence of such an exemption would affect the ability of compliant MSBs to continue conducting lawful business activities already regulated under existing federal legislation. We, the undersigned citizens and residents of Canada, call upon the House of Commons in Parliament assembled to: Amend Bill C-2 to include an explicit exemption under section 77.5(3)(a) for Money Services Businesses that are registered with FINTRAC and operating in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations. AND YOUR PETITIONERS, AS IN DUTY BOUND, WILL EVER PRAY.
Government response
Response by the Minister of Finance and National Revenue Signed by The Honourable François-Philippe Champagne The Government of Canada takes financial crime seriously and is taking bold action to counter criminal threats, protect Canadians, and ensure that crime doesn’t pay. The exploitation of the financial system to launder illicit proceeds supports and perpetuates crimes such as fraud, theft, and extortion, while fueling the drugs, gangs, and violence that threaten the safety of our communities. The government is proposing the creation of the Financial Crimes Agency, Canada’s first-ever federal law enforcement agency dedicated to investigating sophisticated financial crimes like serious fraud and money laundering, and to recovering illicit proceeds. On April 27, 2026, Bill C-29, an Act to Establish the Financial Crimes Agency was tabled, and over $400 million in funding was proposed in the 2026 Spring Economic Update to stand up the Agency. On March 26, 2026, Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, received royal assent. Bill C-12 strengthens anti-money laundering and anti-terrorist financing (AML/ATF) compliance, supervision, and enforcement, including through a 40 times increase in administrative money penalties, so that non-compliance is not treated as the cost of doing business. Economically motivated crimes such as fraud, extortion, and drug trafficking generate cash proceeds and cash remains a preferred payment method for criminals as it is autonomous and easily transferrable. Criminals use anonymous cash transactions to purchase high value goods as a store of value or for resale, or to integrate illicit cash proceeds into the financial system. Money services businesses (MSBs) are an important source of competition in the financial sector, providing services such as remittances, currency exchange, and digital payments, enhancing financial inclusion. However, MSBs also have a very high vulnerability to money laundering and terrorist financing. The 2025 Assessment of Money Laundering and Terrorist Financing Risks in Canada indicates that the specific types of services that MSBs provide that are the most vulnerable include the acceptance of cash. These are: 1) retail multi-service MSBs that offer transactional products and services (i.e., wire transfers, currency exchange, and monetary instruments) that are particularly vulnerable to cash-based money laundering and terrorist financing because they are widely accessible and clients may include high risk actors, such as criminals, politically exposed persons, vulnerable businesses, or clientele in, or interacting with, high-risk jurisdictions; and 2) the transfer of cash to cryptocurrency, which is vulnerable for the same reasons as retail multi-service MSBs, as well as because of cryptocurrency’s pseudonymous, decentralized networks that allow individuals to send or receive funds anywhere in the world. Bill C-2 would address the most common forms of cash-based money laundering and terrorist financing, including through a restriction on large cash transactions of $10,000 or more. To be effective, the restriction must apply as broadly as possible; exempting MSBs would significantly increase risks of money laundering and terrorist financing of the sector. Deposit-taking institutions must be exempted from the restriction to allow cash to enter the financial system, enabling the use of alternate payment methods for transactions over $10,000, such as through e-transfers, wire transfers, cheques, credit and debit cards. While MSBs are regulated federally under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act for AML/ATF purposes, there are important differences between MSBs and deposit-taking institutions. Deposit-taking institutions are the conduit for money to enter the financial system, enabling the flow of credit and investment that is needed for the economy to function. These institutions are subject to significant regulatory oversight at the provincial and federal levels, including for AML/ATF purposes, prudential soundness, market conduct, and market entry. In contrast, MSBs do not take deposits, are not regulated for prudential soundness and have limited market entry controls; Québec is the only province with a specific licensing regime for MSBs. Moreover, registration with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) does not indicate that FINTRAC licenses the business, nor does it mean that FINTRAC endorses its compliance with AML/ATF controls. In March 2026 alone, FINTRAC revoked the registration of 84 MSBs. The impact of the restriction on large cash transactions is expected, in general terms, to be small. Of the approximate 38,000 businesses and professionals regulated for AML/ATF purposes, 98% of large cash transactions reports, which must be submitted to FINTRAC by entities with obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, were submitted by deposit-taking institutions in 2022-23. Approximately 2,778 MSBs submitted 75,246 large cash transactions reports in 2022-23, an average of 27 per MSB. The proposed restriction would not prevent MSBs from continuing to conduct these transactions, only that the cash would need to first be deposited into a deposit-taking institution, before being used to pay for services provided by an MSB. The restriction would reduce administrative burden for MSBs as they would no longer have to submit large cash transactions reports to FINTRAC, while also reducing MSBs’ exposure to money laundering and terrorist financing risks. Nevertheless, the Government of Canada is also aware that the restriction could impact some MSBs more than others, depending on their specific business models and clientele. If passed, the government would consult publicly on implementing regulations before bringing the restriction into force. Affected MSBs are encouraged to engage in this process so the government can better understand the impacts on specific MSBs and potentially take mitigating measures, short of a blanket exemption for all MSBs. Nothing in Bill C-2 would prevent Canadians from continuing to benefit from the services offered by MSBs.