FIT21 Act: US Crypto Market Structure Bill

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.

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.

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.

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.