Recommendation 51

Money Services Business Regulation

Close gaps allowing underground banking to launder funds

Partial
🟡 Status: PartialThis recommendation has been partially addressed. Key elements remain incomplete or are still in progress.

📋 Intended Outcome

A provincial MSB regulatory regime closes the gap allowing unregistered informal value transfer operators and underground banking networks to launder funds.

🏛️ Provincial Action (BC)

BCFSA was granted an expanded mandate to regulate MSBs. A registration and compliance examination regime launched in 2024. Enforcement against unregistered MSBs has commenced.

🇨🇦 Federal Action Needed / Taken

FINTRAC alignment and data-sharing MOU signed. PCMLTFA remains the primary compliance framework; the provincial layer adds enforcement capacity for unregistered operators.

Analysis

The MSB regime is new and enforcement is in early stages. The Cullen Report identified MSBs and informal value transfer systems as critical vectors for the Vancouver Model. Full compliance examination capacity has not been reached.

⚠️ Risk / Outstanding Issues

Crypto-based MSBs (VASPs) are specifically excluded from the current provincial regime, pending further review — a gap the Report anticipated. Unregistered MSBs remain active.