FINTRAC Policy Interpretations (PI-6367*)

"The Government of Canada has made changes to what services make an individual or an entity an MSB in Canada to include virtual currency services; however, these changes are not yet in force. Individuals and entities engaged in the business of dealing in virtual currency services will be MSBs, but cannot yet register with FINTRAC. Before these individuals and entities will be subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), regulations need to be written to define what it means to be engaged in the business of providing services such as dealing in virtual currency.

Until these regulations are drafted and in force you are an MSB, and required to register with FINTRAC, if you are engaged in the business of providing any of the following services:

  • Foreign exchange dealing (conducting transactions where you exchange one type of currency for another currency);
  • Remitting or transmitting funds by any means or through any person, entity or electronic funds transfer network; or
  • Issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments (except for cheques payable to a named person or entity).

Therefore it is only if you are carrying out any of the services listed above, on behalf of clients, that you will be considered an MSB and will be required to register with us."

Our Interpretation of Compliance

As does not engage in any of the 3 activities above it is not considered a reporting entity under the PCMLTFA and thus not obligated or required to register with FINTRAC.

That being said, we do have obligations to our partners to undertake a voluntary compliance program to ensure that we are proactive with the up and coming changes that are being proposed by the New Retail Framework from the Department of Finance Canada, as well as in anticipation that the MSB regulations as administered by FINTRAC will be most likely extended to crypto currencies.

These activities include;

  • Assigning a Compliance Officer,
  • Acquiring Board level approval for the compliance program,
  • Restricting to Canadian clients only with Canadian IPs,
  • Restricting all payments to CAD only,
  • Restricting all payments to Canadian Financial Institutions only,
  • Know Your Customer and Customer Due Diligence,
  • Limits and control based on client verification levels,
  • Transaction Record Keeping,
  • Ongoing monitoring for suspicious activity relating Proceeds of Crime, Money Laundering, and Terrorist Financing,
  • Ongoing Training for all employees, staff, and Management (including board of directors), and,
  • Voluntary reporting to FINTRAC for suspicious activity.


Last updated: February 13, 20-18