Crypto Law Profile

FINTRAC Virtual Currency Travel Rule

Canada’s travel rule requires covered financial entities and money services businesses to transmit prescribed originator and beneficiary information with recordable virtual currency transfers and use risk-based procedures when information is missing.

Canada Effective Regulation Jun 1, 2021

At a glance

Current status In force across Canada since June 1, 2021.
Covered entities Financial entities, MSBs and foreign MSBs when a virtual-currency transfer record is required.
Transfer data Originator and beneficiary names, addresses and any account or reference numbers must accompany covered transfers.
Missing information Recipients must seek missing data and use written risk-based suspend-or-reject procedures.

Overview

The FINTRAC Virtual Currency Travel Rule is the common name for Canada’s information-transmission requirement for certain virtual currency transfers. The binding rule is principally found in section 124.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184. It has been in force since June 1, 2021 and applies nationally to covered financial entities, money services businesses (MSBs) and foreign money services businesses (FMSBs). FINTRAC administers the federal anti-money laundering and anti-terrorist financing regime and publishes guidance explaining the requirement.

What the FINTRAC virtual currency travel rule requires

For a virtual currency transfer covered by section 124.1, the sending entity must include identifying information for both sides of the transfer. The prescribed information is the name and address of the person or entity that requested the transfer, plus any account number or other reference number that exists. The same categories of information are required for the beneficiary.

  • Originator information: name, address and any account or other reference number.
  • Beneficiary information: name, address and any account or other reference number.
  • Incoming transfers: the receiving entity must take reasonable measures to ensure the required information accompanies the transfer.

FINTRAC describes this as information that travels with the transfer. The agency also states that information received under the travel rule cannot be removed. The rule is intended to preserve traceable identifying data as value moves between covered institutions.

Who is covered and when the rule applies

Section 124.1 names financial entities, MSBs and FMSBs. In the crypto market, the rule is most directly relevant to businesses that transfer or exchange virtual currency and fall within Canada’s MSB or foreign-MSB regime. The regulation is tied to an underlying obligation to keep a virtual currency transfer record; it does not apply to every blockchain transaction simply because the transaction is visible on a distributed ledger.

FINTRAC’s sector guidance links the applicable recordkeeping trigger to transfers of virtual currency equivalent to CAD 1,000 or more, including a transfer made at a client’s request and a receipt for remittance to a beneficiary. This threshold should be distinguished from the separate CAD 10,000 large virtual currency transaction reporting regime. Section 125 of the PCMLTFR provides the conversion method when a transaction is denominated in virtual currency.

Missing information and risk-based decisions

A recipient that obtains a covered transfer without the required information must take reasonable measures to obtain it. Covered entities must also develop and apply written, risk-based policies and procedures for transfers that remain incomplete after those measures. The regulation requires those procedures to determine whether the transfer should be suspended or rejected and what follow-up measures should be taken. FINTRAC’s guidance says the policies should address the circumstances in which a transaction may be allowed, suspended or rejected.

This requirement is part of the entity’s broader compliance program rather than a stand-alone reporting form. FINTRAC may review the process used to collect travel-rule information and the decisions taken when information is missing. The travel rule itself does not replace client identification, record retention, suspicious transaction reporting or large virtual currency transaction reporting obligations that may apply separately. Records required under the PCMLTFR are generally retained for at least five years.

Status and legal history

The broader virtual-currency amendments were registered as SOR/2019-240 on June 25, 2019. A subsequent instrument, SOR/2020-112, registered on May 20, 2020, revised the 2019 package, including section 124.1, before the travel-rule requirements took effect. FINTRAC’s guidance and the relevant regulatory obligations became effective on June 1, 2021.

As of June 25, 2026, section 124.1 remains in force. The Justice Laws consolidation is current to May 26, 2026 and lists the section’s amendment history as SOR/2019-240 and SOR/2020-112. The label “FINTRAC Virtual Currency Travel Rule” is therefore best treated as an editorial short title for a requirement contained in the PCMLTFR, not as the official title of a separate Canadian statute.

Key provisions

Originator and beneficiary information

Covered transfers must carry the requester’s and beneficiary’s names, addresses and any account or other reference numbers.

Transfer data Jun 1, 2021 Source

Outgoing and incoming transfer duties

Covered entities must include the information when sending and take reasonable measures to ensure it accompanies transfers they receive.

Transfer handling Jun 1, 2021 Source

Risk-based handling of missing data

Written policies must determine whether to suspend or reject a transfer when required information remains unavailable and identify follow-up measures.

Compliance program Jun 1, 2021 Source

Recordkeeping trigger and threshold

Section 124.1 applies when a virtual-currency transfer record is required; FINTRAC guidance links applicable transfer records to CAD 1,000 or more.

Record keeping Jun 1, 2021 Source

Separate from large-transaction reporting

The travel rule is not a separate reporting requirement; distinct rules govern large virtual-currency transaction reports at CAD 10,000.

Reporting distinction Jun 1, 2021 Source

Timeline

  1. Virtual-currency framework registered

    SOR/2019-240 registered the broader AML/CFT amendments that introduced virtual-currency reporting and recordkeeping provisions.

    Enacted Source
  2. Travel-rule amendment registered

    SOR/2020-112 revised the 2019 package, including section 124.1, before the travel-rule requirements took effect.

    Enacted Source
  3. Virtual-currency travel rule took effect

    Section 124.1 and FINTRAC’s related guidance became operative for covered virtual-currency transfers.

    In force Source

Who it affects

Actors

Department of Finance Canada, FINTRAC

Asset classes

Virtual currency

Official sources

Editorial note

“FINTRAC Virtual Currency Travel Rule” is an editorial label, not the title of a standalone enactment. The binding requirements are principally in section 124.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, read with the Act and related recordkeeping provisions. FINTRAC guidance explains application but is not itself the regulation.