What the introduced legislation could mean for businesses and cryptocurrency services
Businesses that accept large cash payments, money services businesses and crypto ATM operators could face additional restrictions and registration requirements under federal legislation introduced on November 3, 2026.
Bill S-8, titled the Combatting Financial Crimes and Drug Trafficking Act, proposes restrictions on cash transactions of $10,000 or more and on cash deposited by one person into another person’s account. It would also tighten screening for money services businesses and establish new rules for crypto ATM operators.
However, these measures are proposals. The supplied government sources do not establish that Bill S-8 has passed Parliament, received Royal Assent or entered into force.
What Bill S-8 proposes
Bill S-8 would amend the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations.
The business-related proposals covered by the official sources include:
- Restricting large cash transactions of $10,000 or more.
- Restricting third-party cash deposits, described as cash deposited by one person into another person’s account.
- Reducing the ownership threshold connected to criminal record checks for owners or investors in money services businesses.
- Expanding FINTRAC’s ability to refuse or revoke money services business registrations.
- Making it a criminal offence to operate a crypto ATM that is not licensed as a money services business in a province or territory.
- Applying enhanced federal regulatory requirements to crypto ATMs not covered by the proposed ban.
The complete statutory language was not included in the supplied sources. As a result, the full definitions, exemptions, penalties and compliance procedures cannot yet be described from this material.
Proposed restriction on cash transactions of $10,000 or more
The bill proposes a restriction on large cash transactions of $10,000 or more. This could affect businesses that accept cash payments at or above that amount if the proposal is enacted and brought into force.
The official material does not explain whether related cash transactions would be combined, or aggregated, when applying the threshold. It also does not identify a period over which transactions might be assessed. Businesses should therefore not treat the threshold as either strictly per transaction or cumulative based on the supplied information.
Deposit-taking institutions, including banks and credit unions, would be exempt from the proposed large-cash-transaction restriction. The backgrounder says this would allow cash to continue flowing into the financial system.
This stated exemption concerns the large-cash-transaction restriction. The supplied sources do not establish that it would exempt banks and credit unions from every proposed rule involving third-party cash deposits.
How the third-party deposit proposal differs
The proposed third-party deposit restriction concerns one person depositing cash into another person’s account.
The official sources do not state that a business depositing its own cash into its own account would be prohibited. Businesses should not assume that an ordinary deposit of their own cash is covered by the proposed third-party restriction.
Further operational details, including the complete scope of the restriction and any applicable exceptions, are not established by the supplied material.
Tighter screening for money services businesses
Bill S-8 would expand the registration screening and enforcement framework for money services businesses.
The backgrounder identifies a current ownership threshold of 20 per cent for criminal record checks involving owners or investors in a money services business. The proposal would reduce that threshold to five per cent, increasing the number of owners or investors potentially covered by the checks.
The proposal would also expand FINTRAC’s ability to refuse or revoke a money services business registration. A business could be ineligible for registration under the federal anti-money-laundering law if its registration as a payment service provider had been refused or revoked under the Retail Payment Activities Act for national security reasons.
Bill S-8 would also permit temporary suspension of all money services business registrations or specified classes of registrations. It could support enhanced due diligence or temporary restrictions on prescribed domestic transactions in prescribed circumstances.
These are not established as current registration requirements under the supplied sources.
Proposed crypto ATM licensing rule and timing
The bill would make it a criminal offence to operate a crypto ATM that is not licensed as a money services business in a province or territory. It does not propose banning every crypto ATM.
Under the proposal, licensed and regulated crypto ATMs could continue to operate, subject to applicable requirements. Canadians could also continue using regulated in-person and online cryptocurrency platforms.
| Proposed crypto ATM measure | Conditional timing |
|---|---|
| Enhanced federal regulatory amendments | Proposed to come into force 90 to 180 days after Royal Assent |
| Ban on crypto ATMs not licensed as money services businesses in a province or territory | Proposed to come into force 18 months after Royal Assent |
These periods are conditional on Royal Assent. The supplied sources do not establish that Royal Assent has occurred, and they do not provide all operational details for provincial or territorial crypto ATM licensing.
Do You Need to Do Anything?
No immediate change to cash acceptance, deposit practices or crypto ATM operations is established by the supplied sources.
Businesses that could be affected may wish to monitor Bill S-8 for:
- Parliamentary passage and Royal Assent.
- Regulations explaining how the proposed restrictions would operate.
- Commencement dates for the cash, deposit and money services business measures.
- Detailed licensing and regulatory requirements for crypto ATM operators.
- Definitions, exemptions, offences and penalties contained in the final legal framework.
Money services businesses and crypto ATM operators can review the proposals, including the five per cent ownership threshold and licensing provisions, but should not treat them as current legal requirements based on these sources.
Bottom Line
Bill S-8 could affect businesses accepting cash transactions of $10,000 or more, people making third-party cash deposits, money services businesses and crypto ATM operators.
For now, it remains introduced legislation. The official sources do not establish an effective date for the proposed cash-transaction, third-party deposit or money services business measures. The crypto ATM implementation periods would begin only in relation to Royal Assent, which the supplied sources do not establish has occurred.
Official Government Sources
- Department of Finance Canada news release on the introduction of Bill S-8
- Department of Finance Canada backgrounder on the proposed measures
This article provides general information based on official Canadian government sources. Government programs, amounts, eligibility rules and deadlines can change. Check the official sources linked above for information specific to your situation.