Anti-Money Laundering
Consulting Services & Strategies

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Dealers in Virtual Currency


On July 10, 2019, updates to Canada’s anti-money laundering (AML) and counter terrorist financing (CTF) legislation were published to recognize digital currencies, such as Bitcoin (BTC) and Litecoin (LTC), as being “currency” as defined by Canadian regulators. This means that dealers in virtual currency will be considered reporting entities under Canadian legislation and must be registered as money services businesses (MSBs), and have AML compliance programs in place, by June 1, 2020.

MSBs that operate in Canada are subject to Canadian AML and CTF requirements.  The Canadian regulator is the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).  MSBs that do business in Québec are also regulated by the the Autorité des marchés financiers (AMF).  The AMF is the body mandated by the government of Québec to regulate the province’s financial markets.

By June 1, 2020, dealers in virtual currency will be able to register as MSBs with FINTRAC and report certain types of transactions. Prior to this, a pre-registration can be completed. There are no charges for registration with FINTRAC. In the meantime, we recommend putting an AML compliance program in place.

Additionally, as an organization that collects personal information (PI), The Office of the Privacy Commissioner of Canada will govern your practices regarding personal information. Industry members may also be subject to additional provincial level requirements, depending on where you’re doing business.

How Outlier Can Help

Outlier can design plain language AML and CTF compliance program components to help you meet your obligations.  The documentation that we create is intended to work with your existing compliance regime and business practices.

In all of our engagements, we look for ways to streamline your existing practices and empower business, while mitigating your regulatory risk.  Our consultants have completed work for both provincially and federally regulated financial services companies that includes:

We also offer customized training packages that incorporate your practices including specialized training for:

If you have been contacted by a regulator and require immediate assistance, please contact us.