Administrative monetary penalty on MP Technology Services Ltd.

[2025-12-18]

MP Technology Services Ltd., a subsidiary of MoonPay Inc. and a Seychelles-incorporated entity that was determined to be a foreign money services business operating in Canada, was imposed an administrative monetary penalty of $536,853.35 on November 20, 2025, for committing 4 violations. The violations were found during the course of a compliance examination.

Nature of violation

Violation #1

Failure to report the final receipt of an international electronic funds transfer of $10,000 or more in a single transaction, together with the prescribed information– Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 30(1)(c)

FINTRAC examined MP Technology Services Ltd.’s reporting of incoming electronic funds transfers. Of the incoming transfers reviewed, FINTRAC identified 4 that were not reported to FINTRAC as required. FINTRAC found that the missed reporting was likely a consequence of the lack of documented internal procedures pertaining to the electronic funds transfers reporting obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.

Failure to submit a prescribed report, such as an Electronic Funds Transfer Report, results in a loss of intelligence for FINTRAC, and may prevent it from using that information to carry out its mandate per paragraphs 40 (b) and 40 (d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

In this case, violation #1 is classified by regulations as a Minor violation. The imposed penalty takes into account the criteria in section 73.11 of Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #2

Failure of an entity to develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, are approved by a senior officer – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(1) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(b)

FINTRAC determined that the policies and procedures used by MP Technology Services Ltd. to fulfill its compliance obligations during the examination period were inadequate and incomplete. FINTRAC found that the policies and procedures documents were not tailored to Canadian legislation and regulations – specifically the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations – and were missing several requirements. Specifically, FINTRAC found deficiencies in key areas such as:

• The policies and procedures were void of any details on Ministerial Directives and the actions required to be taken.
• The policies and procedures did not document the statutory and regulatory requirement to report Suspicious Transaction Reports to FINTRAC, as prescribed by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations.
• The policies and procedures did not document how Terrorist Property Reports would be submitted to FINTRAC. Specifically, the procedures for reporting by fax or mail without delay to FINTRAC, as well as disclosing the information regarding the transaction or proposed transaction to the Royal Canadian Mounted Police or the Canadian Security Intelligence Service, were not documented.
• The procedures pertaining to Politically Exposed Persons (PEPs) and Heads of International Organizations (HIOs) were missing several key requirements necessary for full compliance. Specifically, they were missing procedures relating to the monitoring and identification of domestic PEPs or HIOs.
• The policies and procedures failed to document the requirement to report electronic funds transfers to FINTRAC.

Policies and procedures are critical to a compliance program as they communicate the important principles of compliance and standards that employees and delegated persons with compliance responsibilities must meet. Documented policies and procedures also serve to ensure clarity and consistency in business operations. Failing to develop, apply, and keep written compliance policies and procedures up to date can result in not meeting other requirements set out in the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated Regulations, and undermines sound business practices designed to minimize a business’ exposure to money laundering and terrorist activity financing.

Violation #2 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #3

Failure to assess and document the risk, taking into consideration prescribed factors – Proceeds of Crime (Money Laundering) and Terrorist Financing Act, subsection 9.6(2) and Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations, paragraph 156(1)(c)

FINTRAC determined that MP Technology Services Ltd.’s risk assessment procedures were not tailored to Canadian legislation. Moreover, FINTRAC found that the risk rating methodology that was being applied to MP Technology Services Ltd.’s Canadian business relationships was finalized and implemented after the examination period. As such, FINTRAC found that MP Technology Services Ltd. failed to adequately document and assess the risk of its business relationships, while taking into consideration the prescribed factors.

Assessing and documenting money laundering and terrorist financing risks ensures that reporting entities are aware of their potential exposure and vulnerability. Failing to assess and document the risks of money laundering and terrorist financing prevents reporting entities from identifying areas of its operations that are vulnerable to being exploited for these purposes and prevents appropriate mitigation measures from being put in place. This can also lead to failing to identify high-risk clients and business relationships for which enhanced risk mitigation measures must be applied. This can further result in the failure to detect and report suspicious transactions to FINTRAC.

Violation #3 is classified by the regulations as a Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Violation #4

Failure to report financial transactions that occurred in the course of its activities and in respect of which there are reasonable grounds to suspect that the transactions are related to the commission or the attempted commission of a money laundering or a terrorist activity financing offence – Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the Act), section 7

FINTRAC's examination revealed that MP Technology Services Ltd. failed to report 4 attempted financial transactions that occurred in the course of its activities and in respect of which there were reasonable grounds to suspect that the transactions were related to the commission of a money laundering or terrorist financing offence.

During the assessment, FINTRAC reviewed the organization’s list of declined (attempted) transactions and identified 4 instances where the obligation to report suspicious attempted transactions was not met. The organization provided a list of 261 attempted transactions and advised that these transactions were declined due to heightened risk pertaining to various red flag indicators. FINTRAC’s review found that a majority of these transactions were declined due to wallet addresses being flagged by transaction monitoring systems for having direct or indirect exposure to darknet marketplaces, sanctioned entities, or child sexual abuse material. While the clients were off-boarded due to the risk identified, no suspicious transaction report was submitted for the attempted transactions to FINTRAC. Failure to submit a prescribed report, such as a Suspicious Transaction Report, results in a loss of intelligence for FINTRAC, and may prevent it from using that information to carry out its mandate per paragraphs 40 (b) and 40 (d) of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

In these 4 instances, MP Technology Services Ltd. failed to submit suspicious transaction reports to FINTRAC despite known indicators of potential money laundering or terrorist financing, as outlined below:

• Funds or virtual currency are added or withdrawn from a virtual currency address or wallet with direct and indirect exposure links to known suspicious sources, including darknet marketplaces, mixing/tumbling services, questionable gambling sites, illegal activities (for example, ransomware) and/or theft reports.
• Use of virtual currencies to fund a virtual currency account, convert funds and/or transfer funds to another virtual currency wallet, obtain a cryptocurrency loan or withdraw funds in cash.
• Transactions involve persons or entities identified by the media, law enforcement and/or intelligence agencies as being linked to criminal activities.

Violation #4 is classified by the regulations as a Very Serious violation. The imposed penalty takes into account the criteria in section 73.11 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and section 6 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations.

Related link

• News release: FINTRAC imposes an administrative monetary penalty on MP Technology Services Ltd.