Unlike the EU’s MiCA CASP framework, Canada does not require substantial local substance or resident directors for MSB registration. Companies must appoint a Compliance Officer to oversee AML programmes. We can provide an outsourced Compliance Officer solution for a Canadian-resident fractional Compliance Officer appointment.
We provide substance solutions to meet FINTRAC and Bank of Canada (RPAA) compliance requirements, including assistance with setting up a local office and outsourcing a part-time fractional Compliance Officer. Our services cover ongoing training, operational support and compliance management to support your regulatory obligations. For an in-depth view on when an outsourced Compliance Officer is appropriate and how the role works in practice, see Compliance Officer outsourcing in Canada.
Compliance Officer responsibilities:
- Implementing and overseeing AML programmes as required by PCMLTFA and RPAA.
- Transaction monitoring, reporting obligations, and risk‑based compliance controls.
- Filing Suspicious Transaction Reports (STRs), Large Cash Transaction Reports (LCTRs), and Large Virtual Currency Transaction Reports (LVCTRs) with FINTRAC.
- Conducting Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Ongoing Due Diligence (ODD) for crypto and financial transactions.
- Ensuring record-keeping compliance and adherence to FATF Travel Rule requirements.
The specific compliance staffing and operational requirements depend on your business model, risk profile and transaction volumes. We provide customised recommendations following a preliminary analysis of your regulatory needs. Our scope of work, deliverables and indicative pricing for a fractional Compliance Officer appointment and AML programme support are set out on our Canada MSB compliance outsourcing page.