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Version date: 4 March 2021 - onwards

9.1. Identifying the VASP population

9.1.1. Canada

283. There are a number of factors that pose challenges during the identification of the VASP population in a jurisdiction. Despite the challenges, early outreach and engagement can help with estimates and complement analysis and research. Canada introduced regulation for VASPs in July 2020. In November 2019, FINTRAC invited VASPs to register early. This enabled the authorities to better anticipate the resources required for supervision and to develop its supervisory strategy. The approach also benefitted the VASPs, as they were able to better understand the requirements with early engagement with the regulator. Although VASP regulation is new in most jurisdictions, this does not mean that all entities within the population are new to regulation. There are a number of examples where FIs, in particular money service businesses involved in cross border exchanges, have integrated a VA exchange component into their business model and where casinos exchange fiat to crypto for their customers. This reiterates the importance of supervisor co-operation, particularly where there are multiple supervisors with entities that provide VASP services, where this may not be their primary activity.