Karsten Wenzlaff, Advisor
August 26th, 2025
Bitcoin ATM Guidance | May 16, 2024

Image: FINTRAC
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) has issued a Sectoral and Geographic Advisory "The Role of Virtual Currency Automatic Teller Machines in Laundering the Proceeds of Crime" to highlight the risks and provide guidance to businesses, financial institutions, and the public. Cryptocurrency has revolutionized the financial landscape, offering unprecedented accessibility and anonymity. However, these advantages also attract illicit activities. One growing concern is the use of virtual currency automated teller machines (ATMs) in laundering proceeds of crime.
Virtual currency ATMs, also known as Bitcoin ATMs, are internet-linked terminals allowing users to exchange fiat currency, such as Canadian dollars, for cryptocurrencies. Unlike traditional ATMs, these machines do not require a bank account, directly connecting users to the virtual currency exchange. While most transactions are legitimate, the ease of converting cash to crypto makes these ATMs an attractive tool for money laundering.
FINTRAC's advisory identifies significant risks associated with virtual currency ATMs. Based on suspicious transaction reports, key hotspots include the Greater Toronto Area, Greater Montréal Area, and Metro Vancouver, with notable volumes of suspicious activities also in Edmonton, Calgary, Winnipeg, Nelson, Abbotsford, Victoria, Ottawa, and Hamilton.
These machines are pivotal in the "placement stage" of money laundering, where illicit cash is converted into virtual currency, making the source of funds difficult to trace. Criminals use various techniques to obscure the identity of those controlling the funds, including falsified identities and money mules.
The advisory highlights several trends and techniques used by criminals:
FINTRAC emphasizes the importance of compliance. Virtual currency ATM operators must implement robust policies, procedures, and internal controls, including client identification and ongoing monitoring of high-risk transactions.
Failure to comply with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act) can result in severe penalties, including fines up to CAN $2,000,000 and imprisonment.
Consumers are urged to be cautious of scams involving virtual currency investments. Fraudulent schemes often solicit investments through social media or impersonate government agencies to extort payments. Individuals should thoroughly research any virtual currency exchange or investment opportunity and be wary of offers that seem too good to be true.
If you encounter suspicious transactions or suspect money laundering or terrorist financing activities, report them to your financial institution and FINTRAC. In urgent cases, contact local law enforcement. Victims of fraud are encouraged to report to the Canadian Anti-Fraud Centre.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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AI Report | May 8, 2024

Image: CFTC-TAC Report - Responsible AI in Financial Markets Opportunities, Risks, Recommendations
On May 2, 2024, the Commodity Futures Trading Commission's Technology Advisory Committee (TAC), sponsored by Commissioner Christy Goldsmith Romero, released a comprehensive report titled, "Responsible AI in Financial Markets" (see: release here). This report addresses the need for responsible AI practices to safeguard financial markets amid the evolving AI landscape, especially with the introduction of generative AI.
The committee of esteemed AI experts made several key recommendations to ensure that AI systems used in financial markets are transparent, fair, robust, and privacy-respecting. These include leveraging existing efforts by the White House and Congress, developing an AI Risk Management Framework in line with NIST guidelines, and enhancing AI governance both at the firm and regulatory levels. The report also emphasizes the importance of continued dialogue and engagement with industry stakeholders to align AI usage in financial markets with responsible practices.
The TAC’s report is an important step in addressing the complex interplay between AI and financial markets. It advances the groundwork for responsible governance and regulatory oversight, ensuring that as AI technologies evolve, they do so in a way that safeguards the integrity of financial markets and protects consumers. The recommendations provided are set to guide future regulatory practices and stimulate further discussion among stakeholders in the financial ecosystem.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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AML/AMF | May 6, 2024

Image: Freepik
The US Department of Justice's is investigating TD's role in facilitating illicit fentanyl profits intensifying apprehensions regarding the bank's compliance practices. The allegations, involve the bank's ties to a US$653 million drug money-laundering case sparking concerns among investors, regulators, and industry observers globally.
According to Gabriel Dechaine, National Bank of Canada analyst, the investigation by the U.S. Justice Department is centered on allegations that Chinese drug traffickers utilized TD Bank, reportedly resorting to bribing TD employees in the process. According to Dechaine, the collective fines may reach a staggering $2 billion. Additionally, regulators may impose constraints, such as limitations on balance sheet expansion, potentially impacting the bank's operations over an extended period.
TD's market capitalization plummeted by approximately $10 billion since the revelations surfaced. The sharp decline in stock prices underscores investor anxieties and underscores the imperative for robust risk management and regulatory compliance within the financial sector.
Elizabeth Goldenshtein, TD Bank Spokesperson:
"Criminals constantly seek to use banks to launder money. Regrettably, our U.S. (anti-money laundering) program did not effectively thwart these activities. This is unacceptable, and we must and we will do better,"
Despite the turmoil, TD's leadership has acknowledged the gravity of the situation and pledged to bolster its anti-money laundering (AML) controls through substantial investments in personnel and technology. CEO Bharat Masrani's commitment to fortifying the bank's compliance infrastructure reflects a proactive stance in addressing regulatory lapses and restoring stakeholder trust.
Looking ahead, TD's efforts to rectify its compliance deficiencies and rebuild its reputation will be closely scrutinized. The bank's ability to implement robust AML controls, foster a culture of accountability, and navigate regulatory challenges will shape its trajectory and impact the broader financial ecosystem.
For fintech stakeholders, it's critically important to have adequate compliance measures and proactively manage risk. As regulatory scrutiny intensifies and market dynamics evolve, fintech entrepreneurs and investors must remain vigilant and adapt accordingly.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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