RUEN
Payment terminal and coins next to a sealed folder

Registering a Canadian MSB for a crypto payment platform

Result

The platform is listed in the FINTRAC public MSB register

The client received a working compliance program, not just a number in the register.

  • ClientCrypto payment platform from Europe
  • PracticeFintech
  • JurisdictionsCanada (FINTRAC); Quebec (AMF, where required)

The task

A platform for exchanging fiat and cryptocurrencies planned to enter the Canadian market and serve customers in Canada. As the business had no Canadian legal entity, it had to register as a foreign MSB (FMSB) before starting operations. The client did not fully understand the scope of the compliance requirements or the real timeline of the procedure.

Challenges and risks

  • Heightened regulatory attention to crypto MSBs and the risk of fines for incomplete compliance
  • Registration is required before operations start, and the client has no Canadian legal entity
  • Unclear scope of compliance requirements and realistic timeline

What we did

  1. Confirmed that the activity qualifies as an MSB
  2. Drafted a written AML/ATF program: policies, procedures, risk assessment, training and independent audit
  3. Assembled the FINTRAC package: corporate data, ownership information and certified criminal record certificates for key individuals
  4. Filed the application through the FINTRAC online system and handled communication with the regulator
  5. Prepared the client for talks with Canadian banks, explaining the difference between FINTRAC requirements and bank onboarding

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