By Terrance S. Carter and Adriel N. Clayton

As reported in the June 2025 and August 2025 Charity and NFP Law Updates, the federal government introduced omnibus Bill C-2, the Strong Borders Act on June 3, 2025 proposing extensive amendments to laws relating to border security, immigration, and anti-money laundering. Among other measures, Bill C-2 proposed new restrictions on large cash donations and expanded powers for the Canada Border Services Agency (CBSA) and law-enforcement agencies to investigate organized crime, money laundering, and terrorist financing. However, Bill C-2 quickly attracted significant public attention and parliamentary debate due to the scope of its proposed new enforcement powers, including access to personal information and authority to search postal mail.

In response to concerns raised over the summer, the government announced in a news release on October 8, 2025 that it was introducing Bill C-12, the Strengthening Canada’s Immigration System and Borders Act, in order to “enable Parliament to pass [certain] priorities to protect Canadians while permitting additional time to evaluate the other measures announced in June 2025” through Bill C-2. The overall goal of the new Bill is to advance less contentious measures from Bill C-2 while giving Parliament more time to review other provisions. As explained by Public Safety Minister Gary Anandasangaree, Bill C-12 was introduced after the government “heard concerns from Canadians over the summer” but remains committed to “equipping our border and law enforcement agencies with the authorities and resources they need” to keep communities safe.

Bill C-12 does not replace Bill C-2. No amendments have been made to Bill C-2 itself; rather, provisions from Bill C-2 that are duplicated in Bill C-12 will later be removed from Bill C-2 to avoid overlap. This means both Bills will now move through Parliament on separate tracks – Bill C-12 focusing on measures the government wishes to advance more quickly, and Bill C-2 continuing in its original form. This dual-track approach enables the government to move forward with measures it considers urgent – such as those addressing organized crime, fentanyl trafficking, and money laundering – while giving legislators and the public additional time to evaluate provisions that have generated greater discussion, particularly those concerning data access and surveillance powers.

For charities and not-for-profits (NFPs), the key takeaway is that Bill C-2 remains a possibility for now and in this regard still includes the proposed prohibition on accepting cash donations of $10,000 or more. This provision (discussed in the above linked articles) would amend the Proceeds of Crime (Money Laundering) and Terrorist Financing Act to make it an offence for charities and other entities that solicit public donations to accept large cash payments, either in a single transaction or a series of related transactions. While this measure has not yet been enacted, charities should continue to monitor its progress and be prepared to adapt their donation practices should the restriction be adopted.

The government describes Bill C-12 as a means to strengthen immigration and border security, protect Canadians, and keep communities safe. However, for the purposes of the charitable and NFP sector, the most relevant aspect of Bill C-12 is its continuation of broader anti-money-laundering and financial-transparency measures first introduced in Bill C-2. These include stronger penalties under Canada’s AML/ATF Regime, and the addition of the Director of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) to the Financial Institutions Supervisory Committee, enhancing inter-agency cooperation.

By dividing Bill C-2 into two pieces of legislation, the government is signaling a continued focus on financial accountability and international enforcement and attempting to allow the less controversial elements of Bill C-2 to move ahead more quickly, while deferring debate on measures that have drawn public criticism, such as concerns related to privacy and human rights issues.

In summary, Bill C-12 represents an arguably more moderate approach of the government’s border and financial-security agenda, while Bill C-2 remains before Parliament in its original form. For charities and NFPs, this means continued attention should be given to the evolving federal approach to cross-border transactions, transparency, and compliance. Even though Bill C-12 introduces no new sector-specific obligations, both Bills reinforce a trend toward greater scrutiny of financial flows and heightened expectations for accountability – developments that organizations with international or cross-border operations should monitor closely as Parliament considers both pieces of legislation.

​Read the October 2025 Charity & NFP Law Update