Reported by Julie Searle, Zach McHenry, and Daniella Torrealba

(Excerpt shared below. To read full report, go to: https://www.nortonrosefulbright.com/en-us/knowledge/publications/383b5ba5/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.

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 Forceaimed 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.