Canada announces new financial crimes agency: What US businesses need to know

On October 20, 2025, Canadian Finance Minister Francois-Philippe Champagne announced plans to implement heightened financial regulatory and enforcement measures.

The announcement comes in advance of Canada’s upcoming federal budget (Budget 2025), which the Prime Minister is expected to unveil on November 4. As outlined in the Finance Minister’s recent announcement, the upcoming budget will include policies to combat financial fraud in two primary ways.

First, Budget 2025 will outline Canada’s plan for introducing the “National Anti-Fraud Strategy,” a national strategy to adopt increased anti-fraud measures. Previewing these changes, the Finance Minister said that Canadian government will introduce legislative amendments to the Bank Act that would require Canadian banks to adopt new fraud detection and reporting measures, such as obtaining customer consent for certain account features, allowing customers to set transaction limits and reporting fraud data to the Financial Consumer Agency of Canada. The announcement also highlighted a forthcoming Code of Conduct for the Prevention of Economic Abuse that will set voluntary expectations for financial institutions to identify, prevent and respond to economic abuse.

Second, Budget 2025 will announce the creation of a new Financial Crimes Agency. This agency will lead investigation into sophisticated financial crimes, including money laundering, large-scale fraud and recovery of criminal proceeds. The Finance Minister, in conjunction with other government officials, will introduce legislation by Spring 2026 to establish the Financial Crimes Agency. By centralizing investigative and enforcement authority for financial crimes, the Financial Crimes Agency will supplement the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), which functions as Canada’s financial crime intelligence hub akin to the United States’ Financial Crimes Enforcement Network (FinCEN)—the agency that administers and enforces the Bank Secrecy Act, collects and analyzes Suspicious Activity Reports and disseminates financial intelligence to United States law enforcement and regulators.

Implications for United States businesses

United States businesses should be aware of the following implications that may arise from Canada’s plans to seek heightened anti-fraud regulatory and enforcement measures.

Increased scrutiny of cross-border financial activities

Businesses with Canadian subsidiaries or counterparties—particularly those involving financial institutions—should expect increased compliance obligations and enforcement visibility. Expanded Canadian investigative efforts and reporting requirements may implicate books and records, employees and/or systems for companies based in the United States, potentially triggering internal reviews or regulatory inquiries.

Potential for follow-on investigations by United States regulators

Increased Canadian enforcement measures could prompt parallel or follow-on inquiries from United States regulators. Notably, Canada’s new “National Anti-Fraud Strategy” complements many of the US Department of Justice’s white-collar enforcement priorities and policies, as set forth in a memorandum the agency issued in May of this year (available here). Among other enforcement priorities, the DOJ memorandum emphasizes that the agency will continue to focus on investigating and prosecuting complex money laundering schemes, as well as financial fraud that harms United States investors and consumers, such as Ponzi schemes, investment fraud and elder fraud. Moreover, United States regulators will likely benefit from increased information collected by Canadian reporting and enforcement measures. For example, earlier this year, Canada announced the creation of a Canada-US Joint Strike Force aimed to combat money laundering, among other border security priorities. Given the common interest in anti-fraud enforcement, Canadian investigations that implicate cross-border businesses may attract corresponding enforcement measures from United States regulators.

In light of this regulatory landscape, businesses operating across borders must prioritize risk management and compliance. Practical risk management steps for companies to consider include the following.

Monitor cross border exposure

Inventory Canadian subsidiaries, branches, vendors, distributors, payment flows and data systems that could be implicated by Canadian AML/fraud inquiries or new bank-driven controls.

Update AML and anti-fraud controls

Refresh KYC (Know Your Customer) and CDD (Customer Due Diligence) protocols, SAR monitoring and ensure company policies align with both United States and Canadian reporting requirements. Consider adding additional compliance training opportunities for employees.

Refine playbook for enforcement inquires

Update internal investigation protocols and prepare for potential regulator inquires. This may include designating a cross-border response team (e.g., legal, compliance, privacy, investigations) and establishing internal procedures to maintain transparency with regulators, such as policies for voluntary self-disclosure.

Canada’s plans to implement heightened financial regulatory and enforcement measures represents a potential escalation in cross-border financial crime enforcement and underscores the importance of maintaining robust AML, fraud prevention and investigation frameworks. United States businesses operating in or alongside Canada must stay alert to the developing compliance obligations and enforcement trends.