In proposed Bill C-2, restrictions were introduced disallowing acceptance of cash payments, donations or deposits over $10,000 for most organizations, except Banks and Credit Unions with an additional blanket banning of all 3rd party cash deposits (regardless of amount, with exceptions to be prescribed).
After receiving much public critique, proposed Bill C-12 was introduced shortly after to replace proposed Bill-C2, eliminating these controversial measures.
But guess what? The proposed regulations were not left behind entirely - in actuality, they were paused - and are now BACK on the table...this time in the Government of Canada’s Fall 2025 Budget (also known as “Canada Strong”).
How this will ultimately shape within the regulatory landscape in 2026 is still to be determined - but critiques of these proposed regulations remain, including:
🔴 The possibility of unnecessary administrative burdens for developing new processes. There are many situations where cash deposits over $10,000 (especially since $10,000 is quite a low deposit amount) or transfers by a third-party over are indeed legitimate. For example, a family member sending funds to a relative in a foreign country, employee deposits into a company bank account or a parent depositing money into their child’s bank account all can constitute legitimate transaction types that should not be flagged or require enforcement – ultimately prohibiting these types of deposits could lead businesses to develop new processes to accommodate the law, resulting in administrative burdens.
🔴 Too many legitimate transactions will be prohibited. Because acceptance of cash transactions over $10,000 will be banned for all businesses in Canada (excluding banks), many payments that are for legitimate reasons will be banned and might adversely affect groups that have large reserves of cash required for a transaction (for example, immigrants who are trying to pay for housing or school who may not have the correct banking channels established in Canada to send digital payments or inter-family transactions, for example, repaying a loan to a family member).
🔴 Negative impacts and losses for charities and non-profits that often rely on large cash donations. Many charities and non-profits also rely on very large cash donations to fulfill their mandates. These new policies would introduce a roadblock for charities and non-profits generating donation revenue...which is meant for good.
If you have any questions about how these regulatory changes if enacted could affect your business or clients, reach out to us today to connect with an AML expert.