This record-breaking fine, announced on October 22, 2025, marks the largest penalty ever issued by FINTRAC and highlights the increasing scrutiny of virtual currency businesses in Canada.

The compliance examination revealed multiple severe violations during July 2024, including:

• Massive Reporting Failures:

  • 1,068 instances of failing to submit suspicious transaction reports
  • 1,518 cases of failing to report virtual currency transactions exceeding $10,000

• Systemic Compliance Deficiencies:

  • Failure to comply with a Ministerial Directive
  • Lack of proper written compliance policies and procedures
  • Inadequate risk assessment documentation
  • Failure to update registration information

This enforcement action comes at a crucial time for Canada's rapidly expanding virtual currency sector. Sarah Paquet, Director and Chief Executive Officer of FINTRAC, emphasized the unprecedented nature of this enforcement action, stating: "Given that numerous violations in this case were connected to trafficking in child sexual abuse material, fraud, ransomware payments and sanctions evasion, FINTRAC was compelled to take this unprecedented enforcement action."

This case highlights several critical points for the virtual currency industry:

1. Increased Regulatory Focus: FINTRAC has significantly stepped up enforcement, issuing 23 Notices of Violation in 2024-25 alone, totaling over $25 million in penalties.

2. Virtual Currency Vulnerabilities: The rapid expansion of the virtual currency sector has brought increased risks of:

   • Money laundering
   • Terrorist financing
   • Sanctions evasion

3. Compliance Framework Importance: The case underscores the critical need for robust anti-money laundering and anti-terrorist financing compliance controls in the virtual currency sector.