Equibytes Inc. (Equibytes) is committed to preventing, detecting and deterring money laundering and terrorist financing.
While Equibytes is not currently considered a reporting entity under current Canadian anti-money laundering (AML) and counter terrorist financing (CTF) legislation, Canadian federal Bill C-31, passed in 2014, stipulated that “dealers in virtual currency” will be considered money services businesses (MSBs). Draft regulations published in the Canada Gazette on June 9, 2018 provided additional insight in relation to the proposed regime.
On a provincial level, we have obtained licensing with the Authorité des marchés financiers in Québec. To date, this is the only province to have enacted separate MSB related requirements. These provincial requirements have taken a broader view than existing federal level requirements, having included in their mandate automated teller machines and cheque cashing businesses.
As Equibytes is engaged in the purchase and sale of virtual currency, it is probable that we will be captured by this definition, once it has been enacted. Additionally, we understand that our business model carries some risk related to money laundering and terrorist financing, and that the mitigation of these risks is necessary to satisfy our Senior Management team, and financial services suppliers.
While legislation specific to dealing in virtual currency has not yet been enacted, Equibytes has developed an AML and CTF compliance program. These are voluntary measures that mimic existing requirements for MSBs. Where it is not yet possible for Equibytes to comply with existing federal level requirements for MSBs (for instance, MSB registration with the Financial Transaction and Reports Analysis Centre of Canada, also known as FINTRAC, and certain types of regulatory reporting), Equibytes will continue to monitor requirements as they evolve.
Our policy against money laundering (AML) is as follows:
1. Transactions less than $ 1000, no verification is required. Optional SMS phone confirmation.
2. We ask for customer identification for transactions over $ 1000.
3. We verify customer identification for transactions over $ 3000.
4. Report “large cash transactions” over $ 10,000;
5. Report any suspicious activity within 30 days.
For more information on AML in Canada, please visit the following websites:
FINTRAC
http://www.fintrac-canafe.gc.ca/fintrac-canafe/definitions/money-argent-eng.asp
http://www.canafe-fintrac.gc.ca/fintrac-canafe/definitions/money-argent-fra.asp
AMF
https://lautorite.qc.ca/en/professionals/inspection/general-information/money-services-businesses-inspections
https://lautorite.qc.ca/professionnels/inspection/informations-generales/secteur-des-entreprises-de-services-monetaires
If you have questions pertaining to Equibytes compliance policies or processes, please contact us.