Who must register
Businesses providing foreign exchange dealing, money transferring, issuing or redeeming payment instruments, dealing in virtual currency, or operating certain payment services to Canadian clients generally need to register with the federal financial intelligence unit.
Firms outside Canada serving Canadian customers may fall under the foreign money services business category.
What registration involves
An application covering ownership, directors, business activities, jurisdictions served and banking arrangements, supported by a written compliance programme.
Registration is a regulatory listing rather than a prudential authorisation, so there is no capital requirement in the way a banking or e-money licence imposes one.
Ongoing obligations
Appointing a compliance officer, maintaining written policies, training staff, keeping prescribed records, reporting suspicious and large transactions, and completing a periodic independent effectiveness review.
Registration must also be renewed on schedule, and material changes reported promptly.
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