Crypto MSB Compliance

cryptocompliancethatkeepsyouregistered.builtbypeoplewhoranitatscale.

FINTRAC's 2025 National Risk Assessment identified MSBs and virtual currency dealers as the highest-risk segment in the Canadian financial system. Q1 2026 saw 86 MSB revocations — many crypto-linked. The enforcement campaign is accelerating.

theproblem.

Compliance programs written in 2021 or earlier are almost certainly deficient relative to current PCMLTFA obligations. Crypto-specific risks — wallet analysis, 24-hour aggregation, virtual currency thresholds — require specialized knowledge that generic compliance shops don't have.

FINTRAC actively revoking crypto MSB registrations at an accelerating pace
Compliance programs that haven't been updated since initial registration
No internal expertise for wallet-level analysis or VC-specific STR identification
Voluntary disclosure coordination needed for missed reports
Banking partners demanding evidence of a functioning compliance program

whatwecover.

End-to-end compliance for virtual currency dealers, crypto exchanges, and Bitcoin ATM operators.

Named CAMLO on your registration

A CAMS-certified compliance officer on your FINTRAC registration with the authority and expertise to implement and maintain your AML/ATF program.

STR filing & wallet-level analysis

Suspicious transaction identification that includes wallet-level analysis, 24-hour aggregation rule logic for VC transactions, and LCTR filing for transactions exceeding $10,000 thresholds.

KYC/KYB framework for crypto onboarding

Client identification and verification procedures designed specifically for virtual currency activities — walk-in customers, recurring accounts, and business relationships.

FINTRAC administration & reporting via Comply+

Adding and removing ATM locations, MSB updates and renewals, and automated transaction reporting via direct API submission. Transaction data goes in, compliant reports come out.

whyus.

was CFO & CCO of Bitcoin Well (TSXV:BTCW) — a publicly listed, multi-entity crypto company. He built the compliance program from scratch, managed FINTRAC reporting, and navigated the regulatory environment these prospects deal with daily. brings payments compliance depth from Peloton Technologies, including RPAA and enterprise AML program management. Together they understand crypto compliance from both the operator and regulator perspectives.

CPACFACAMS

Luke ThibodeauCPA · CFA · CAMSFounder and CEO

Luke is a finance and compliance operator who works hands-on with bitcoin-native companies, fintechs, and MSBs as a fractional CFO and CCO through Rockwell Advisory Group. As former CFO & CCO of Bitcoin Well (TSXV:BTCW), he built and ran the finance, compliance, and governance functions across a publicly listed, multi-entity crypto company from the ground up.

Today he brings that same operational depth to clients navigating treasury management, FINTRAC compliance, financial reporting, and corporate governance. Whether it's standing up a compliance program for a new MSB, managing multi-entity consolidations, or advising on AI strategy through Rockwell AI, Luke operates as an embedded member of the team rather than an outside advisor. He also founded Comply+, a RegTech platform automating FINTRAC reporting for Canadian MSBs, born directly from the pain points he encountered building compliance workflows by hand.

Charles KlineCAMSHead of Compliance

Charles leads compliance and risk for Rockwell Advisory Group, helping fintechs, MSBs, and payments companies build AML and KYC programs, tighten onboarding and monitoring, and stay aligned with FINTRAC and Canadian regulatory expectations. CAMS-certified, he works as an embedded operator: policies, controls, training, audit readiness, and the day-to-day execution that backs them up.

Previously he served as Compliance Officer and Director of Risk & Compliance at Peloton Technologies, running the enterprise AML program (including FCAC and RPAA), leading the RPAA roll-out for a large organization, training analysts on KYC, sanctions, and FINTRAC reporting, leading the first external Compliance Effectiveness Review, and rebuilding onboarding for FINTRAC KYC. Before that he was Head of Underwriting & Risk at Orchard Technologies, building PayFac-ready underwriting and AML frameworks and automated onboarding from early stage through Global Payments partnership. At Lightspeed Commerce (Payments), he scaled underwriting from a solo function to a global team of twenty across North America, EMEA, and APAC while keeping fraud losses below industry benchmarks.

Get your crypto compliance sorted