Canada

Key Requirements

• Register as Money Services Business with FINTRAC for virtual currency exchange and transfer activities.
• Implement Travel Rule procedures reporting beneficial ownership for transactions exceeding CAD 10,000.
• Establish Compliance Officer responsible for AML/CFT program and FINTRAC reporting obligations.
• Maintain detailed transaction and customer records for minimum 5 years with FINTRAC reporting requirements.
• Develop comprehensive AML/CFT program including customer due diligence and suspicious transaction reporting.
• Conduct annual AML/CFT compliance assessments with documented findings and remediation actions.
• Maintain professional indemnity insurance and implement cybersecurity procedures per FINTRAC guidance.

Application Process

1. 1.Complete FINTRAC MSB registration form online through FINTRAC portal with business information.
2. 2.Prepare AML/CFT compliance program documentation including policies, procedures, and staff training plan.
3. 3.Document Travel Rule compliance procedures for beneficial ownership reporting on transactions exceeding CAD 10,000.
4. 4.Establish Compliance Officer role with documented responsibilities and reporting lines.
5. 5.Submit record-keeping procedures documentation confirming 5-year minimum retention.
6. 6.Submit MSB registration to FINTRAC and monitor for approval notification.
7. 7.Receive FINTRAC registration confirmation and activate AML/CFT compliance procedures.
8. 8.Commence virtual currency business operations under FINTRAC regulatory oversight.

Ongoing Obligations

• File Suspicious Transaction Reports (STRs) with FINTRAC within 30 days of detection of suspicious activity.
• Submit Suspicious Transaction Actuals Reports (STARs) on prescribed dates providing aggregate suspicious activity data.
• Maintain customer identification records including beneficial owner information for all accounts.
• Implement Travel Rule procedures for transactions exceeding CAD 10,000 with originator/beneficiary tracking.
• Conduct quarterly compliance reviews with documented assessment of AML/CFT procedure effectiveness.
• Maintain detailed transaction logs with customer information, amounts, dates, and counterparties for 5 years minimum.

Key Requirements

• Register with provincial securities commission as Restricted Dealer under National Instrument 31-103.
• Maintain minimum capital requirements per provincial securities regulations (CAD 25,000-100,000 depending on province).
• Establish Compliance Officer and Chief Financial Officer with Canadian securities experience and regulatory approval.
• Implement know-your-customer procedures with suitability assessments for crypto product recommendations.
• Establish segregated customer accounts with independent custodian holding all customer assets.
• Maintain errors and omissions insurance of minimum CAD 250,000 to CAD 1,000,000 depending on business size.
• Implement cybersecurity and operational resilience procedures meeting CSA standards for business continuity.

Application Process

1. 1.Select provincial jurisdiction and obtain Provincial Securities Act regulatory guidance on Restricted Dealer registration.
2. 2.Prepare detailed business plan describing crypto trading services, customer protections, and operational procedures.
3. 3.Document minimum capital adequacy per province (CAD 25,000-100,000) with bank statements and financial documentation.
4. 4.Establish Compliance Officer and CFO with documented securities industry experience and regulatory approval.
5. 5.Prepare Form 33-109F2 and supporting documentation for Restricted Dealer registration submission.
6. 6.Submit registration application with all supporting documentation to provincial securities commission.
7. 7.Engage with provincial regulator addressing information requests and compliance clarifications (6-12 months).
8. 8.Receive provincial securities commission approval and commence crypto trading operations.

Ongoing Obligations

• File annual audited financial statements demonstrating minimum capital maintenance per provincial requirements.
• Submit quarterly compliance certifications documenting AML/CFT procedures and customer protection effectiveness.
• Maintain detailed customer account records with KYC information, suitability assessments, and transaction history.
• File Suspicious Transaction Reports with FINTRAC for activities exceeding federal thresholds.
• Conduct annual compliance audits with documented findings and remediation of identified gaps.
• Maintain errors and omissions insurance continuously with annual renewal certificates to provincial regulator.
• Report material incidents including cybersecurity breaches, fraud, or customer complaints to provincial commission within specified timeframe.

Key Requirements

• Register as Portfolio Manager or Investment Fund Manager under National Instrument 31-103 with provincial securities commission.
• Maintain minimum working capital of CAD 100,000 with quarterly capital adequacy reporting.
• Establish Chief Compliance Officer and Chief Financial Officer with documented investment management and regulatory experience.
• Develop detailed fund offering documents including prospectus or offering memorandum meeting provincial requirements.
• Implement comprehensive AML/CFT procedures with investor identification and beneficial owner verification.
• Establish segregated investor accounts with independent IIROC or CIPF-member custodian.
• Maintain professional indemnity insurance of minimum CAD 250,000-2,000,000 depending on assets under management.

Application Process

1. 1.Select provincial jurisdiction and obtain investment fund regulatory guidance from provincial securities commission.
2. 2.Prepare detailed investment fund business plan describing fund strategy, crypto asset allocation, and investor targeting.
3. 3.Document CAD 100,000 minimum working capital with bank statements and audited financial documentation.
4. 4.Establish Chief Compliance Officer and Chief Financial Officer with investment management regulatory experience.
5. 5.Prepare offering documents (prospectus or offering memorandum) meeting provincial securities requirements.
6. 6.Prepare National Instrument 31-103 registration application with supporting governance and compliance documentation.
7. 7.Submit investment fund manager registration application to provincial securities commission.
8. 8.Engage with provincial regulator addressing information requests and fund documentation reviews (4-8 months).
9. 9.Receive provincial approval and commence crypto fund offering to qualified investors.

Ongoing Obligations

• Maintain minimum CAD 100,000 working capital with quarterly capital adequacy reporting to provincial regulator.
• File annual audited financial statements with regulatory-approved auditors demonstrating ongoing compliance.
• Prepare and deliver annual fund performance reports to all investors with updated valuation and returns.
• Maintain investor account records with KYC information, suitability documentation, and transaction history.
• File Suspicious Transaction Reports with FINTRAC for activities meeting federal reporting thresholds.
• Conduct annual compliance audits with investment fund offering and operational effectiveness assessment.
• Maintain professional indemnity insurance continuously with annual renewal certificates to provincial commission.