Bill S-8: What Canada's new financial crimes bill means for businesses

On November 3, 2026, the federal government introduced Bill S-8, An Act respecting certain measures relating to proceeds of crime, terrorist financing, sanctions evasion and the detection of non-mailable matter transmitted by post (“Bill S-8”) as part of its plan to “better detect, disrupt and deter economic crimes."

As set out in the Department of Finance’s news release issued concurrently with Bill S-8, the bill proposes to fight financial crimes through five different measures:

1. Addressing criminal abuse of money services businesses (“MSBs”);
2. Cracking down on unlawful crypto ATMs;
3. Addressing some of the most common forms of money laundering;
4. Cracking down on the unlawful use of the mail system; and
5. Clarifying public-to-private information sharing.

Bill S-8 is part of Canada’s strong commitment to combating financial crime in recent years, as confirmed in Budget 2026. Budget 2026 lists it alongside Bill C-29, which would “stand up the Financial Crimes Agency as Canada's new lead enforcement agency.”

We detail Budget 2026’s impact on the financial services sector and National Anti-Fraud Agenda in our Budget 2026: Financial Institutions update.

Tighter control of money services businesses 

Canada’s 2025 National Risk Assessment found that MSBs are vulnerable to money laundering, terrorist financing, sanction evasion, fraud, and other national security threats.

Bill S-8 proposes to amend the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) to address criminal abuse of MSBs by:

• Introducing new Ministerial powers, including:
  • the ability to direct FINTRAC to deny or revoke MSB registration;
  • the ability to temporarily suspend the registration of all MSBs or certain classes of MSBs;
  • the ability to issue directives requiring enhanced due diligence for, and the issuance of regulations to temporarily limit or prohibit, certain domestic transactions in prescribed circumstances;
• Making MSBs ineligible for registration under the PCMLTFA if their registration as a payment service provider is refused or revoked under the Retail Payment Activities Act for national security reasons;
• Expanding FINTRAC’s ability to refuse or revoke registrations;
• Raising the threshold of criminal record checks from 20% ownership to 5%, which will increase the number of criminal record checks for owners or investors in an MSB; and
• Ensuring FINTRAC has up-to-date information about MSBs, including information regarding the commencement of business, financial information, and services provided by MSBs.

A new criminal offence for unlicensed crypto ATMs and enhanced regulatory requirements

The Department of Finance has concluded that crypto ATMs “have become a primary method for scammers to extract cash from victims and for criminals to place their cash proceeds of crime in Canada.”

They are also used to evade sanctions and fund terrorism. According to the Canadian Anti-Fraud Centre, Canadians are estimated to have lost between $142 million and $284 million due to fraud facilitated by crypto ATMs in 2024, with studies finding that between 85 and 98% of crypto ATM transactions are linked to illicit activity.

Bill S-8 would:

• make it a criminal offence to operate a crypto ATM that is not licensed as a money service business in a province or territory; and
• propose enhanced federal regulatory requirements for ATMs that are not subject to the ban that “reflect the highest regulatory standards that currently exist internationally.”

The criminal ban would come into force 18 months following Royal Assent, and the regulatory amendments would come into force 90 to 180 days following Royal Assent.

Restrictions on cash transactions over $10,000 and third-party cash deposits 

According to the Department of Finance, cash remains a “preferred payment method for criminals,” and Canada is the only G7 country, other than Japan, that does not have a framework to restrict or regulate large cash transactions across the economy.

Bill S-8 proposes to amend the PCMLTFA to:

• restrict large cash transactions of $10,000 or more; and
• restrict the depositing of cash by one person to another person’s account (i.e., third-party cash deposits).

Deposit-taking institutions (i.e., banks and credit unions) would be exempt from the large cash transaction restriction.

Enhanced law enforcement powers to search and seize mail in transit

To assist in Canada’s effort to combat organized crime and contraband trafficking, the Department of Finance states that Bill S-8 would address the existing limits in law enforcement’s ability to search and seize mail in transit, and amend the Canada Post Corporation Act to permit law enforcement to search and seize mail if they have lawful authority.

These amendments would apply in suspected non-compliance cases under the Cannabis Act, but would not allow postal inspectors to open letters, as confirmed by the Department of Finance.

Information flowing from police to regulated businesses 

In February 2025, Canada launched a new Integrated Money Laundering Intelligence Partnership (“IMLIP”) between law enforcement and Canada’s big banks, aimed at bolstering Canada’s response to organized crime and sophisticated money laundering schemes.

To support IMLIP, Bill S-8 would amend the PCMLTFA and Personal Information Protection and Electronic Documents Act to allow regulated businesses to receive and use information disclosed by law enforcement for anti-money laundering purposes.

Cyber and privacy implications

Bill S-8 and related Budget 2026 initiatives further touch on how personal information is accessed, shared and protected.

The government recognizes that fraudsters are “increasingly exploiting digital platforms, telecommunications services, and the financial system” and that these actors “may attempt to exploit MSBs by accessing sensitive personal and financial information or by leveraging remittance channels to facilitate foreign interference, cybercrime, and other illicit activities.”

In response, the government is developing Canada’s first National Anti-Fraud Strategy, which brings together financial institutions, digital platforms and telecommunications companies in a cross-sectoral approach to protect Canadians from fraud schemes as they evolve.

Our previous post detailed consultations on the National Anti-Fraud Strategy from April 2026.

Since then, the government has stated that feedback was “overwhelmingly supportive of a fraud strategy that recognizes the fact that fraudsters are exploiting gaps between banks, telecommunications services providers, and digital platforms, and that none of these organizations can fight fraud alone.”

As the cornerstone of the Strategy, the government intends to introduce a legislated Multi-Sector Anti-Fraud Framework. To protect Canadians, organizations will be required to “prevent, detect, disrupt, and respond to fraud, and to work with each other, across sectors, to resolve fraud-related complaints.”

The Framework will be complemented by other legislative amendments to implement sector-specific anti-fraud requirements that “protect users of financial, telecommunications, and digital platform services,” including:

• amending the Bank Act to cap maximum consumer liability at $0 for any form of transaction resulting from unauthorized access to a consumer’s bank account, in the absence of gross negligence on their part;
• amending the Telecommunications Act to give the Canadian Radio-television and Telecommunications Commission (“CRTC”) the authority to introduce fraud prevention obligations for telecommunications service providers, and to collect and publish information about how prevalent fraudulent telecommunications are; and
• amending Canada’s Anti-Spam Legislation (“CASL”), including to give the CRTC the authority to proactively disclose information to domestic law enforcement and/or national security organisations.

The government has stated that it will consult on draft legislation and amendments before they are introduced.

Related privacy reforms under Bill C-36

Budget 2026 further refers to Bill C-36, the Protecting Privacy and Consumer Data Act, introduced in June 2026, which would require organizations to be clearer about how they collect and use personal data, introduce tougher penalties for non-compliance and strengthen transparency around the use of personal information in automated systems.

The government has committed to establishing a new Digital Safety and Data Protection Commission of Canada, which would be responsible for the Act. Budget 2026 also proposes to improve information sharing between FINTRAC and the Office of the Superintendent of Financial Institutions, “ensuring the appropriate safeguards for consumer information.”

Key takeaways

• Canada’s financial crime regime is evolving. Bill S-8 signals further regulatory and enforcement changes as part of Canada’s broader effort to combat financial crime.
• Fraud remains a central priority. The government continues to focus on private market participants taking more responsibility in combatting fraud.
• Financial services, telecommunications, and digital services organizations should closely monitor these developments and their impact on their operations in Canada and abroad. For example, Canada’s recent release has stated that the government’s “immediate priority will be to put in place common cross-sector rules,” followed by sector-focused requirements.
• From a cyber and privacy perspective, organizations should prepare for increased information sharing. Organizations should assess whether they are positioned to receive and govern information disclosed by law enforcement, map the data flows that cross-sector fraud information sharing will require, consider participating in the upcoming consultation on the Multi-Sector Anti-Fraud Framework, and continue to assess the requirements proposed in Bill C-36.

McCarthy Tétrault draws on the combined expertise of our White Collar Defence and Investigations, Financial Institutions Regulatory Group, Fintech Group, International Trade & Investment, Technology and Cyber/Data groups to deliver coordinated advice on Canadian compliance and related legal issues.

If you have questions about how these developments may affect your business or organization, please contact one of the authors or another member of our team.