Compliance Policy

FINTRAC Policy Interpretations - Providing a Virtual Currency Service

"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 Proactivity & Cooperation

Considering does not qualify as an MSB (at this time) we are not considered a reporting entity and therefore not obligated to fulfill FINTRAC's reporting requirements about certain transactions. However, in our own efforts to be proactive with the forthcoming law and to prevent Money Laundering and Terrorist Financing within our country and internationally, we have structured the operations of our business to limit amounts purchased well below amounts MSBs have to report on. In addition, we restrict visitors from countries outside of Canada, only process credit cards in CAD issued by Canadian financial services companies and mandate verification of a Canadian mobile phone number registered to a major Canadian carrier. Irrespective of MSB eligibly, we make it our duty to report transactions we belive may be related to money laundering or terrorist financing and will provide law enforcement with supporting evidence upon request.

Last Updated: June 28, 2016