When should MSB verify the client? Verification methods for individuals. Confirmation of the existence of legal entities. References to FINTRAC sector guides.
Legal basis: PCMLTFA and FINTRAC requirements. Categories of documents subject to mandatory retention. Retention periods: minimum 5 years and exceptions.Technical requirements for organizing record storage. Critical errors and FINTRAC penalties.
Official FINTRAC statistics and factors behind discrepancies. Step-by-step process: where does the time go? Sticking points: where do applications get stuck? How to speed up the process: practical recommendations. Conclusions: planning timelines with a buffer.
The de-risking phenomenon: when banks say «no». What banks expect from MSBs: compliance as a pass. Documents for opening an account: preparing the package. Types of bank accounts for MSBs. Strategies in case of bank refusals.
Types of activities requiring an MSB license. Basic obligations and the registration process. Risks of non-compliance and practical case studies. MSB vs Foreign MSB: choosing the optimal structure. Common mistakes and how to avoid them?
FINTRAC definition: fundraising for third parties. How does the market interpret the MSB status of platforms? Obligations after registration with FINTRAC. Penalties and consequences of unregistered operations.
Types of services: transfers, currency exchange, cryptocurrency. Reporting thresholds and limits under PCMLTFA. Informal transfer systems: hawala/hundi. AML/KYC programs for MSBs.
MSB activities — currency exchange, money transfers, cryptocurrencies. Customer identification and reporting requirements. AML/CTF compliance program. Common mistakes when registering an MSB.
Obligations to FINTRAC and additional layers of regulation. Physical presence in the province: legal address and office. Local presence: what regulators and banks expect. Trade-offs in choosing a province: taxes, reputation, operating costs.
Risk-based approach of the regulator. Preparing for the audit: documents and logs. What do inspectors check? The inspection process: from notification to conclusions. Typical violations and consequences.
