Stablecoin issuer / redeemer in Canada

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.

EXCHANGE: A crypto exchange serving Canadians registers with FINTRAC as a money services business (or foreign MSB) for dealing in virtual currency and, where it trades crypto contracts, with the securities regulators; since 6 August 2024 the CSA expects such platforms to register as investment dealers and join CIRO, and no longer grants time-limited restricted dealer registration or accepts new pre-registration undertakings.

CUSTODY: Under the standard pre-registration undertaking in CSA Staff Notice 21-332 (22 February 2023), a crypto trading platform holds client crypto assets in trust for clients, separate from its own assets, with an Acceptable Third-party Custodian (such as a Canadian custodian or Canadian financial institution, or another custodian meeting the notice's criteria or consented to by the regulator), and keeps at least 80% of the value of client crypto assets with third-party custodians.

FINTRAC — AML/CFT, MSB registration, transaction reporting

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

CSA Staff Notice 21-327 (16 January 2020) sets out when securities legislation applies to crypto trading platforms; the compliance and registration framework followed in Joint CSA/IIROC Staff Notice 21-329 (29 March 2021), the day the OSC told platforms to start registration or face enforcement action, and the OSC began proceedings against a non-compliant offshore platform on 25 May 2021.

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.

Registration framework is established through National Instrument 31-103 (NI 31-103) — Registration Requirements, Exemptions and Ongoing Registrant Obligations

NI 31-103 s. 12.1 requires a registered firm's excess working capital (Form 31-103F1) not to fall below zero for 2 consecutive days, with minimum capital of $25,000 for an adviser, $50,000 for a dealer and $100,000 for an investment fund manager; dealers must also maintain bonding or insurance (s. 12.3). Investment dealers that are CIRO (formerly IIROC) members are exempt from ss. 12.1 and 12.3 under s. 9.3(1) unless also registered as investment fund managers.

Under NI 31-103 s. 11.3(1) every registered firm must designate an individual registered in the category of chief compliance officer; the Exempt Market Products Exam is a proficiency option only for an exempt market dealer's CCO (s. 3.10), alongside the PDO or Chief Compliance Officers Qualifying Exam and 12 months of relevant experience.

Registration authority rests with each provincial or territorial securities regulator; restricted-dealer applicants apply separately to each regulator, and the OSC registers crypto trading platforms for Ontario through its own decisions, with Cybrid Canada registered for Ontario only as of 25 September 2026.

CSA members coordinate registration through the passport system (Multilateral Instrument 11-102) and, with Ontario, the interface system: a firm registering in several provinces or territories files through the passport and interface system, except restricted dealers, which apply separately to each regulator.