Common AML program failures for Canadian MSBs
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
The compliance program failures that most frequently produce FINTRAC findings are structural, not incidental — and most are preventable.
Cross-border payment flows into and out of Canada engage MSB registration requirements that depend on where activity occurs and which entities perform it.
Canadian crypto exchanges are required to register as MSBs with FINTRAC and maintain a full AML compliance program — the obligations are specific and the enforcement record is growing.
SaaS platforms that embed payment functionality need to assess whether their role in the fund flow creates MSB exposure independent of their payment partners.
Canadian fintech regulation turns on what a product does, not what it is called — and the analysis starts with the flow of funds.
Marketplaces that handle funds between buyers and sellers face MSB registration questions that the platform label does not resolve.