Compliance Policy

FINTRAC Policy Interpretations - Providing a Virtual Currency Service

The Financial Transaction and Reports Analysis Centre of Canada (FINTRAC) is Canada’s anti money laundering (AML) and counter terrorist financing (CTF) financial intelligence unit (FIU) and regulator. They have stated that: "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. Nonetheless, we are proactive in developing voluntary compliance measures that we expect to be in lines with the forthcoming regulatory updates. We strive to prevent money laundering and terrorist financing within our country and internationally. The steps that we have taken include the implementation of an AML and CTF Compliance program with:

  • A designated Compliance Officer;
  • Documented policies and procedures;
  • A documented Risk Assessment;
  • An ongoing training program; and
  • Periodic reviews of the effectiveness of our compliance program and operations.

In addition, we have operational processes in place that include:

  • Transaction limits and monitoring;
  • Customer verification and identification; and
  • Risk-based measures.

We believe that the program that we have implemented is on par with those of regulated entities in Canada. Additional information about our commitment to compliance and our compliance program may be obtained by contacting us directly.

Last Updated: March 26, 2018