The two regimes at a glance
Two registrations matter for a crypto business serving Canadians. FINTRAC is the federal anti-money-laundering regulator: anyone dealing in virtual currency for Canadians must register as a money services business (MSB) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Revenu Québec licenses MSBs that serve Québec residents under the province's Money-Services Businesses Act — a second, separate approval with its own fit-and-proper checks.
Neither registration is an endorsement of a company's finances. Both mean the business has identified itself to the regulator, has a compliance program and is subject to reporting obligations and examinations. What matters to you as a client is simpler: an unregistered platform is operating illegally in Canada, and you have no regulator to complain to.
FINTRAC MSB registration
Since June 2020, "dealing in virtual currencies" — exchanging crypto for fiat or other crypto, or transferring it for clients — makes a business an MSB. Registration is done through FINTRAC's MSB portal, is public, and must be renewed every two years. A registered MSB has to appoint a compliance officer, write and follow a compliance program, run a risk assessment, train staff and have the program reviewed every two years.
The client-facing obligations are what you notice: identity verification before a transaction, record-keeping on transactions of $1,000 CAD and up, and mandatory reports to FINTRAC — large virtual currency transactions of $10,000 CAD or more within 24 hours, and any transaction the business suspects is linked to money laundering. FINTRAC can levy administrative penalties and publishes them; the largest to date have exceeded $7M CAD.
Revenu Québec MSB licence
Québec is the only province with its own MSB regime. Any business offering money services — including virtual-currency exchange — to people in Québec needs a licence from Revenu Québec, in addition to FINTRAC registration. The application includes a security clearance from the Sûreté du Québec for directors, officers and significant shareholders, disclosure of every branch and agent, and proof of the business's Québec presence.
The licence is published in Revenu Québec's public register and must be kept current: changes in directors, shareholders or business locations have to be declared within days, not at renewal. Operating in Québec without it is an offence with fines from $2,000 CAD to $50,000 CAD per infraction for a first offence, and the regulator can order the business to stop serving Québec clients immediately.
How to verify a registration
Do not take a footer badge at face value — check the registers yourself, both take under a minute. For FINTRAC, open the MSB Registry search and search the legal company name; the entry shows the MSB number, the activities registered (look for "dealing in virtual currencies") and the registration status. For Québec, use Revenu Québec's Register of Money-Services Businesses and confirm the licence number and category.
Three things to cross-check: the legal name on the register must match the company you are contracting with (not just a brand), the status must be active, and the registered activity must include virtual currency. A payment-processor or foreign-exchange registration alone does not cover crypto.
Where TokenNest is registered
TokenNest is registered with FINTRAC as a money services business for dealing in virtual currencies and money transferring, and holds a Revenu Québec MSB licence for the Québec market. Both numbers and register links are on our AML/KYC policy page and in the footer of every page, so you can verify them against the registers above rather than trusting the badge.
In practice this is why you verify your identity before your first purchase, why purchases of $10,000 CAD and more are reported to FINTRAC, and why we ask about the source of funds on larger OTC tickets. It is also why your coins leave for your own wallet: registration covers our conduct, not custody, and we prefer not to hold what regulation does not protect.
Common questions
Yes, if it serves Québec residents. FINTRAC registration is federal and mandatory everywhere in Canada; the Revenu Québec licence is required on top of it for any client in Québec. A business registered only with FINTRAC must geo-block Québec or is operating illegally there.
No. Provincial securities regulators separately regulate platforms that hold client crypto in custody or offer crypto contracts. A non-custodial MSB that settles coins to your wallet on the same day, as TokenNest does, is regulated for anti-money-laundering conduct, not as a dealer holding your assets.
Client identification records, transaction records for virtual-currency transfers of $1,000 CAD and up, large-transaction reports for $10,000 CAD and above, and copies of any suspicious transaction reports — all kept for five years and available to FINTRAC on request. Your personal data is held under PIPEDA and, in Québec, Law 25.