Self-custodial wallet / non-custodial software in Canada

FINTRAC — AML/CFT, MSB registration, transaction reporting

Proceeds of Crime (Money Laundering) and Terrorist Financing Act (2000) — AML/CFT, MSB registration

VASP: a crypto platform serving Canadians registers with FINTRAC as a money services business (or foreign MSB) for dealing in virtual currency and, for crypto contracts, with the securities regulators, which since 6 August 2024 expect investment dealer registration and CIRO membership rather than restricted dealer status; Binance, whose principal regulator was the Alberta Securities Commission, announced on 12 May 2023 that it would withdraw from Canada.

CSA — coordinates provincial and territorial securities regulation of crypto trading platforms through CSA Staff Notice 21-327 (16 January 2020) on when securities law applies, Joint CSA/IIROC Staff Notice 21-329 (29 March 2021) on compliance, and the 6 August 2024 expectation that platforms register as investment dealers and become CIRO members.

CSA Staff Notice 21-327, Guidance on the Application of Securities Legislation to Entities Facilitating the Trading of Crypto Assets (16 January 2020), states that a platform is generally not subject to securities legislation only if the underlying crypto asset is not a security or derivative and each contract results in, and is settled by, immediate delivery of the crypto asset to the user.

Ongoing Focus on Unregistered Platforms: Securities regulators continue to target platforms operating in Canada without registration. This often results in cease trading orders, financial penalties, and requirements for platforms to either register or exit the Canadian market.

On 22 Jun 2022 a panel of the Capital Markets Tribunal approved a settlement between the Ontario Securities Commission and Bybit Fintech Limited (British Virgin Islands) for operating an unregistered crypto asset trading platform; Bybit disgorged USD 2,468,910, paid CAD 10,000 toward investigation costs, and gave an undertaking not to open new Ontario accounts or offer new products while registration discussions continue, and to wind up its Ontario operations if they fail.

On 22 Jun 2022 a panel of the Capital Markets Tribunal permanently banned Mek Global Limited (Seychelles) and PhoenixFin Pte. Ltd. (Singapore), together KuCoin, from participating in Ontario's capital markets and ordered an administrative penalty of CAD 2,000,000 plus $96,550.35 in OSC investigation costs for operating an unregistered crypto asset trading platform. Separately, FINTRAC imposed an administrative monetary penalty of $19,552,000 on Peken Global Limited (operating as KuCoin) on 28 Jul 2025 for 3 violations, which Peken has appealed.

On 17 Mar 2022 the Ontario Securities Commission published an undertaking by Binance Holdings Limited and Binance Canada Capital Markets Inc. confirming that activities involving Ontario residents had ceased, after Binance falsely told investors on 29 Dec 2021 that it could keep operating in Ontario. Binance told the Alberta Securities Commission (principal regulator for the CSA) on 2 May 2023 that it would withdraw from Canada and announced the exit publicly on 12 May 2023. FINTRAC imposed an administrative monetary penalty of $6,002,000 on Binance Holdings Limited, as a foreign money services business, on 7 May 2024 for 2 violations; Binance appealed to the Federal Court.