A Mid-year Check-in: White Collar Enforcement And Compliance In Canada

2025 was not a particularly robust year for major white collar prosecutions in Canada. However, that does not mean the risk environment was stagnant. If anything, the year reinforced a different trend. Enforcement, compliance expectations and litigation exposure continue to expand across a range of areas, including anti-money laundering, deceptive environmental marketing, foreign bribery, procurement integrity and fraud prevention.

That shift is taking place against a backdrop of growing concern about the scale and sophistication of economic crime. Canadian Anti-Fraud Centre data indicates that Canadians lost more than $704 million to fraud in 2025 alone, with reported losses since 2022 surpassing $2.4 billion. The same reporting also emphasizes that these figures likely capture only a fraction of the true harm, since most frauds go unreported.¹

At the same time, regulators, courts and enforcement bodies continued to respond to that evolving risk landscape not only through criminal cases, but through compliance frameworks, regulatory oversight and civil litigation. For businesses, the practical message is clear. White collar risk in Canada is no longer measured solely by the number of prosecutions in a given year, but by a broader landscape of investigative, regulatory, reputational and private-law exposure.

With that in mind, we have identified some of the top white collar investigation, defence and compliance developments from 2025 through to early 2026 in our mid-year review.

1. AML enforcement and intelligence-sharing accelerated

The Financial Action Task Force (FATF) is currently finalizing its 2025 mutual evaluation of Canada’s implementation of international anti-money laundering and anti-terrorist financing (AML/ATF) standards. This assessment—the first since 2016—has placed Canada’s AML/ATF regime under heightened scrutiny and has, in recent years, driven it to the forefront of legal and regulatory reform efforts.

In February 2025, the Department of Finance Canada announced the Integrated Money Laundering Intelligence Partnership (IMLIP), a public–private initiative that facilitates the lawful sharing of intelligence on money laundering and organized crime between Canadian law enforcement and major financial institutions. Its membership includes officials from the RCMP’s Federal Policing program and the Chief Anti-Money Laundering Officers of Canada’s major banks, with the Department of Finance Canada and Public Safety Canada supporting its governance and policy framework.

This development set the stage for further financial crime intelligence sharing announcements in 2025.

In March 2025, the Department of Finance Canada announced new amendments to Canada’s AML/ATF regime under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), administered by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). The amendments:

• Expanded AML/ATF obligations to factoring companies, cheque-cashing businesses, and financing and leasing entities.
• Created a framework for private institutions to share information relating to money laundering, terrorist financing and sanctions evasion.
• Reinforced the Canada Border Services Agency’s authorities to combat trade-based financial crime.
• Required the reporting of discrepancies linked to the federal corporate beneficial ownership registry.

The announcement also confirmed that, beginning April 1, 2025, provincial and territorial civil forfeiture offices would begin receiving FINTRAC financial intelligence disclosures, signalling a more integrated enforcement model aimed not only at investigation, but also at the identification and seizure of suspected criminal proceeds.²

In its 2024-25 Annual Report, FINTRAC reported a 40% increase in its assessment activities over the previous year, a pace which appears to have continued through 2025. FINTRAC’s publicly available list of administrative monetary penalties demonstrates a sharp rise in penalties levied by FINTRAC starting in 2025, both in volume and aggregate amount. For businesses, these developments mean a more connected AML system, with more reporting entities, broader reporting requirements, greater information sharing, and a higher risk of enforcement.

The broader enforcement trend is reflected in R. v. Ber, 2025 ABKB 37, where the Alberta Court of King’s Bench imposed a seven-year global sentence on an investment advisor convicted of fraud and accepting a secret commission after placing millions of dollars of high-risk shares in client accounts. Although not a money-laundering prosecution, the decision underscores the judiciary’s continued emphasis on denunciation, deterrence, abuse of trust, and the protection of confidence in financial markets in serious economic crime cases.³

Tightening enforcement: Key active legislative proposals in 2026

Bill C-22, the proposed Lawful Access Act, 2026, suggests that the federal government is also focused on strengthening how financial crimes are investigated.

The Bill would update the rules around access to subscriber and transmission data, clarify when authorities can examine computer data, allow certain requests for data held outside Canada, and require service providers to assist with lawful access requests. In practical terms, it points to a parallel trend. As AML compliance obligations expand, so do the tools available to law enforcement and intelligence agencies to gather digital evidence in complex investigations.⁴

In recent days, the federal government introduced Bill C-29 which proposes to stand up Canada’s Financial Crimes Agency. This Agency is designed to be a specialized hub for the investigation of financial crime and will boast broad information sharing powers. For more details on this bill, see our recent assessment in “Canada is taking a sharper, more coordinated approach to financial crime.”

Also on the legislative agenda is Bill C-2, the Strong Borders Act. This bill would, among other things, eliminate the need for prior judicial authorization in relation to certain information that is provided to law enforcement voluntarily, including subscriber information in exigent circumstances. Some of these provisions constitute a direct response to the Supreme Court of Canada’s decision in Bykovets, which requires the police to obtain prior judicial authorization to obtain an IP address. Bill C-2 also proposes to increase the maximum monetary administrative penalties that may be imposed for certain offences under the PCMLTFA.

For more information, please see:

• Government strengthens Canada’s anti-money laundering framework with new regulatory amendments
• Bill C-22, An Act respecting lawful access
• Bill C-2, An Act respecting certain measures relating to the security of the border between Canada and the United States and respecting other related security measures
• Liberals offer more search, intercept powers to police and CSIS with new bill

2. Canada’s 2025 money-laundering risk assessment supports a “risk-based controls” theme

The federal government’s 2025 Assessment of Money Laundering and Terrorist Financing Risks demonstrates that Canada’s AML/ATF regime is becoming more focused on real-world risks and practical controls. Building on the 2015 and 2023 assessments, the 2025 report introduces a “residual risk lens,” which looks not only at where risks exist, but also at what measures are already in place to address them. In practical terms, the focus is shifting from identifying risks to showing how they should be managed.

That matters for businesses. The report makes clear that reporting entities under the PCMLTFA are expected to use the national assessment when designing their own compliance programs, internal risk assessments, customer due diligence and transaction monitoring. The key message is that AML compliance should not be one-size-fits-all. It should be tailored to identified threats and vulnerabilities within particular sectors and business models and updated as those risks evolve.

The 2025 assessment also highlights that money laundering is closely linked to underlying crimes. Among the principal threats identified are fraud, drug trafficking, human trafficking and auto theft. This is important because it demonstrates that effective AML controls are not just about spotting suspicious transactions, but they also require an understanding of the criminal activity that generates illicit funds in the first place.

That theme is reflected in R. v. Samoodi, 2025 ONSC 4899. In Samoodi, the accused pleaded guilty to laundering proceeds of crime, knowing the funds were derived from fraud over $5,000. The scheme involved a fictitious investment opportunity, overseas victims, and the use of corporate profiles and bank accounts to receive and move fraud proceeds. Although the offender was not the person directly soliciting victims, the court found that he played an integral logistical role in setting up accounts and handling the funds generated by the fraud.⁵

The significance of Samoodi is that it illustrates the exact risk pattern identified in the 2025 assessment namely, how money laundering often supports other crimes rather than operating on its own. The case demonstrates how corporate structures, banking channels and intermediaries can be used to move and hide illegal funds. From a compliance perspective, that is precisely why a risk-based approach matters. Businesses need to look not just for unusual transactions, but for patterns and behaviours linked to known types of fraud.

The decision also reinforces the seriousness with which courts continue to treat laundering tied to fraud. At sentencing, the court emphasized the sophistication of the operation, the number of victims, the offender’s knowledge that he was handling proceeds of fraud, and the significant personal and financial harm suffered by victims. Overall, Samoodi reinforces the broader policy message reflected in the 2025 assessment. Money laundering is not merely a technical issue but plays a key role in enabling serious crime and increasing its impact.

For more information, please see:

• 2025 assessment of money laundering and terrorist financing risks in Canada
• Assessment of money laundering and terrorist financing risks in Canada
• 2025 Assessment of Money Laundering and Terrorist Financing Risks in Canada: Overview

3. Bribery/Anti-Corruption Law had a notable appellate development in 2025

A key appellate decision in 2025 was R. v. Arapakota, 2025 ONCA 660,⁶ which has been described as the first Court of Appeal interpreting the core bribery offence under the Corruption of Foreign Public Officials Act (CFPOA).

The Court upheld the acquittal but clarified two important parts of the offence.

First, it confirmed that there must be a clear exchange, meaning a benefit is given in return for some official action or decision- in other words, there must be an actual or contemplated quid pro quo for a bribery offence to be made out. However, the Crown does not need to point to a specific act in advance.

Second, the Court shed light on the meaning of the term “advantage” in the core corruption provisions in the CFPOA, writing that a benefit or advantage “encompasses a situation only where the beneficiary of a bribe secured (or intended to secure) a material or tangible gain” (para 124). A vague or possible benefit is not enough.

On the facts, the accused paid for a foreign official’s family trip in exchange for the government of Botswana sending him letters confirming its intention to award a contract to his company and confirming the value of the prospective contract. However, the trial judge found that this did not result in any material or tangible economic benefit which did not trigger the core corruption provision of the CFPOA. The Court of Appeal dismissed the appeal.

Arapakota highlights that courts are taking a careful and structured approach to foreign bribery cases. The decision confirms that Canadian prosecutors must establish both a real exchange and a concrete business advantage to meet its case beyond a reasonable doubt. This decision will render corruption prosecutions more challenging in cases where a material or tangible benefit is not made out.

At the same time, the Court noted that other types of conduct may still fall under different parts of the law, which means that how charges are particularized and investigated will remain important in foreign bribery cases.

4. Public procurement fraud became a major practical risk story in 2025

A notable domestic development was the 2026 sentencing decision in R. v. Aquino and Georgiou, 2026 ONSC 984, arising from the St. Michael’s Hospital $300 million redevelopment project.⁷ The Court found that senior executives corrupted the procurement process by secretly sharing confidential bid information and providing strategic guidance to a preferred bidder, leading to fraud convictions.

What stands out in this case is the Court’s focus on the broader harm caused by procurement fraud. The Court held that the misconduct did not merely result in financial loss to the hospital and competing bidders, but undermined the integrity of the procurement process itself, depriving participants of a fair, rule-based selection process and eroding public confidence in public-private partnerships. The Court characterized this loss of confidence as a “profound” harm, even where precise monetary loss could not be quantified.

This case reflects a broader shift in how procurement misconduct is understood and enforced. Courts are increasingly treating it as a serious public and economic issue, not just a technical or contractual problem. That approach aligns with Canada’s federal supplier-integrity regime, including the Office of Supplier Integrity and Compliance, which focuses on whether suppliers involved in misconduct should be suspended or rendered ineligible to contract with government.

Together, these developments signal heightened legal, reputational, and debarment risk for companies operating in public procurement environments.

Conclusion

Heading into 2026, it is clear that the Canadian white collar risk landscape continues to evolve in ways that extend well beyond traditional prosecution. As this year’s developments show, risk is increasingly shaped by regulatory guidance, civil litigation, compliance expectations and reputational exposure across areas such as anti-money laundering, environmental claims, foreign bribery and procurement integrity.

Risk is also manifesting itself more and more through quasi-criminal legislation targeting foreign influence on Canadian political or governmental processes (see for example, the latest on Canada’s foreign agent registry here).

In this environment, proactive risk assessment and well-designed compliance frameworks provide the strongest foundation for business continuity and growth. Organizations that understand where their exposure lies, and that implement practical, evidence-based controls, are better positioned to respond to scrutiny and avoid disruption.

At Gowling WLG, we work with clients to identify, assess and navigate these risks in a practical and strategic way. Developing and maintaining robust compliance programs is not only a defensive measure, but an essential part of operating confidently in today’s complex and evolving Canadian business environment.

Footnotes

1. Dylan Robertson, “Over $704M lost to fraud in 2025, Canadian Anti-Fraud Centre data indicates” (March 6, 2026), online: Law360 Canada.

2. Government of Canada, “Government strengthens Canada’s anti-money laundering framework with new regulatory amendments” (March 7, 2025).

3. R v Ber, 2025 ABKB 37.

4. Bill C-22, An Act respecting lawful access, 1st Sess, 45th Parl, 2025–2026 (first reading 12 March 2026).

5. R v Samoodi, 2025 ONSC 4899.

6. R v Arapakota, 2025 ONCA 660.

7. R v Aquino and Georgiou, 2026 ONSC 984.

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