Fintrac Exempt

Are you Foreign exchange dealing? Includes conducting transactions where you exchange one type of currency for another (for example, exchanging USD for CAD). Answer: No. We Sell physical gold in exchange for money. And we buy physical gold for money. We store, buy and sell gold for a small fee and offer a tokenized version of the gold in holding with which the user can make purchases against that gold until depleted. At any time the user can sell that gold to us or withdraw/transfer the physical gold in multiples of 400 troy oz denominations.

Are you Remitting or transmitting funds from one person or entity to another using an electronic funds transfer network or any other method such as Hawala, Hundi, Fei ch'ien, and Chitti. This includes remitting or transmitting funds (as instructed by your clients) carried out by means of a credit/debit card if the beneficiary has an agreement with the payment service provider that permits payment by that means for the provision of goods and services. Answer: No, the users or entities exchange the tokenized gold directly to other users in exchange for goods and services. The recipient can redeem fiat for the digital tokens by selling the gold or can withdraw/transfer the physical gold.

Are you Issuing or redeeming money orders, traveller’s cheques or anything similar: Is your business issues or redeems money orders, travellers' cheques or other similar negotiable instruments. This does not include cashing cheques made out to a particular person or entity. Answer: No, transactions are conducted on the app using the tokenized gold. Issuance of a pre loaded credit card are in consideration based on the users gold held in the vault.

Are you Dealing in virtual currency: this includes both virtual currency exchange and virtual currency transfer services. Virtual currency exchange services include exchanging: funds for virtual currency, virtual currency for funds, or virtual currency for another virtual currency. Virtual currency transfer services include: transferring virtual currency at the request of a client, or receiving a transfer of virtual currency for remittance to a beneficiary. Answer: No, goods and services are exchanged from peer to peer for tokenized gold added to user wallets. 

Are you a Crowdfunding platform services: the provision and maintenance of a crowdfunding platform for use by other persons or entities to raise funds or virtual currency. Note: FINTRAC is taking the position that persons or entities that provide invoice payment services or payment services for goods and services are engaged in the business of remitting or transmitting funds, or dealing in virtual currency. Answer: No, we do not engage in crowdfunding or fundraising activities.

Are you providing invoice payment services or act as an intermediary between a payer and a payee to make payments to invoices, such as those pertaining to utilities, payroll and commission, mortgage and rent, or tuition Exception: A person or entity that solely receives payments on behalf of the payee to settle a debt, and does not further transfer the payment instructions to the original payee. Answer: No we do not facilitate invoice payment services.

Are you providing payment services for goods or services: receive payment instructions and act as an intermediary between a payer purchasing goods or services and a payee supplying goods or services; the payer consents to make the payment for the goods or services through them; and the payee has an agreement with them to have access to the transfers carried out as payment for the goods or services. Exceptions: A person or entity that solely accepts a payment for goods or services that they supplied to their own customer. A person or entity that solely provides hardware (for example, a physical payment terminal), and does not offer any other associated payment services. Answer: No, we do not act as an intermediary. The user purchases gold and receives tokens for the gold in storage which is then used to purchase goods and services from other users.