Cryptocurrency Regulations in Canada

ByClark

Tariq Ahmad Foreign LawSpecialist

SUMMARY: Canada primarily regulates cryptocurrencies under securities laws. The Canadian Securities Administrators have issued guidance on how the relevant laws may apply to different activities involving cryptocurrencies. It includes information on when coins or tokens may be considered securities and states that each initial coin or token offering must be considered on its own characteristics. Where securities are involved, this may trigger prospectus or registration requirements.

Canada allows the use of digital currencies, including cryptocurrencies. However, cryptocurrencies are not considered legal tender in Canada. Canada’s tax laws and rules, including the Income Tax Act, also apply to cryptocurrency transactions. The Canada Revenue Agency has characterized cryptocurrency as a commodity and stated that the use of cryptocurrency to pay for goods or services should be treated as a barter transaction.

On June 19, 2014, the Governor General of Canada gave his royal assent to Bill C-31, which includes amendments to Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The new law treats virtual currencies as “money service businesses” for purposes of anti-money laundering provisions. The law is not yet in force, pending issuance of subsidiary regulations.

  1. Approach to Assets Created Through Blockchain

According to a recent report on cryptocurrency regulation in Canada, “[t]he general attitude of the Canadian government (including regulatory agencies) to cryptocurrencies has been a mix of caution and encouragement: caution in terms of protecting investors and the public, but encouragement in its support of new technology.”1 Furthermore, “cryptocurrencies are primarily regulated under securities laws as part of the securities’ regulators mandate to protect the public.”2

Canada allows the use of cryptocurrencies as a means of payment.3 According to the Government of Canada webpage on digital currencies, “[y]ou can use digital currencies to buy goods and services on the Internet and in stores that accept digital currencies. You may also buy and sell digital currency on open exchanges, called digital currency or cryptocurrency exchanges.”4 However, cryptocurrencies are not considered legal tender in Canada.5 The Currency Act6 defines “legal tender” as “bank notes issued by the Bank of Canada under the Bank of Canada Act” and “coins issued under the Royal Canadian Mint Act.”7 According to the report referred to above, “[d]espite cryptocurrency not being recognized as legal tender, the Bank of Canada tested Digital Depository Receipts (DDR) as a digital representation of Canadian currency in 2016 and 2017. DDR is a way to transfer central bank money on to a distributed ledger technology platform (DLT, or “blockchain”).”8

  1. Financial Regulation and Consumer Protection

Canada does not have a federal securities regulatory system or authority. Securities regulators from each of the ten provinces and three territories in Canada have joined together to form the Canadian Securities Administrators (CSA), “whose objective is to improve, coordinate and harmonize regulation of the Canadian capital markets.”9 As a result, securities regulations in the provinces and territories “have largely been harmonized.”10

Implications for Offerings of Tokens.13 Further information on these notices is provided below.

the CSA published CSAStaffNotice46-307CryptocurrencyOfferings,11 “which On August 24, 2017, The Financial Consumer Agency of Canada (the Agency) “is a federal agency that oversees compliance of federally regulated financial entities with consumer protection rules.”14 The Agency has a digital currency page which provides information on risks associated with and tips on using digital currencies. According to lawyers from Goodmans LLP, the Agency “has not yet released an official position on how or if it intends to further regulate the space. However, it is possible that as larger Canadian financial institutions begin investing in blockchain and cryptocurrency in their retail operations, the Agency will respond with new rules to satisfy its mandate and protect financial consumers.”15

  1. Anti-Money Laundering Law

On June 19, 2014, the Governor-General of Canada gave his assent to Bill C-31 (An Act to Implement Certain Provisions of the Budget Tabled in Parliament on February 11, 2014, and Other Measures),16 which includes amendments to Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Act. The law treats virtual currencies as “money service businesses” for purposes of anti-money laundering laws.17 As a result of the law, companies dealing in virtual currencies will be required to register with the Financial Transactions and Reports Analysis Centre of Canada (Fintrac), put into effect compliance programs, “keep and retain prescribed records,” report suspicious or terrorist-related property transactions, and determine if any of their customers are “politically exposed persons.”18 The law will also apply to virtual currency exchanges operating outside of Canada “who direct services at persons or entities in Canada.”19 The new amendments also bar banks from opening and maintaining accounts or having a “correspondent banking relationship” with companies dealing in virtual currencies, “unless that person or entity is registered with the Centre.”20

The law was regarded as the “world’s first national law on digital currencies, and certainly the world’s first treatment in law of digital currency financial transactions under national anti-money

laundering law.”21 Although the law has received royal assent it is not yet in force, pending issuance of subsidiary regulations. A March 2018 news report indicated that the government may have been about to issue those regulations,22 but as yet none have been released.

  1. Taxation

Canada’s tax laws and rules also apply to digital currency transactions.23 On March, 6, 2019, it was reported that Bitcoin investors were being targeted with audits by the Canada Revenue Agency (CRA).24 When asked to comment, a media contact at the CRA said in a statement that

[t]he Canada Revenue Agency (CRA) understands that a vast majority of middle-class Canadians pay their fair share, but it remains committed to ensuring that without exception, every taxpayer abides by the same tax laws. As a world-class tax administration, the CRA is also committed to adapting its administration to keep pace with evolving global services and products, and making key investments to effectively address the new ways of doing business in the global economy.

In order to make good on these commitments, the CRA established a dedicated cryptocurrency unit in 2017 to build intelligence, and conduct audits focused on risks related to cryptocurrencies. This unit has enhanced the CRA’s ability to monitor and enforce compliance in areas of emerging risk, including the cryptocurrency space. There are currently over 60 active audits related to cryptocurrency.

The CRA is also committed to helping taxpayers understand their tax obligations when using digital currencies, and to remind them that using digital currency does not exempt consumers from their tax obligations. The CRA has published educational material on its website regarding the tax treatment of dealing in Digital Currency.25

The CRA “has characterized cryptocurrency as a commodity and not a government-issued currency. Accordingly, the use of cryptocurrency to pay for goods or services is treated as a barter transaction.”26 The tax implications of barter transactions “is available by consulting the Canada Revenue Agency’s Interpretation Bulletin IT-490, Barter Transactions.”27 According to the CRA, “[a]ny income from transactions involving cryptocurrency is generally treated as business income or as a capital gain, depending on the circumstances. Similarly, if earnings qualify as business income or as a capital gain then any losses are treated as business losses or capital losses.”28

  1. Payments inCryptocurrencies

Digital currencies are subject to the Income Tax Act (ITA).29 According to the Financial Consumer Agency of Canada, “[g]oods purchased using digital currency must be included in the seller’s income for tax purposes.”30 On the issue of taxation, the CRA adds that,

[w]here digital currency is used to pay for goods or services, the rules for barter transactions apply. A barter transaction occurs when any two persons agree to exchange goods or services and carry out that exchange without using legal currency. For example, paying for movies with digital currency is a barter transaction. The value of the movies purchased using digital currency must be included in the seller’s income for tax purposes. The amount to be included would be the value of the movies in Canadian dollars.31

According to the CRA, “[w]here an employee receives digital currency as payment for salary or wages, the amount (computed in Canadian dollars) will be included in the employee’s income pursuant to subsection 5(1) of the Income Tax Act.”32 The CRA has also said that “GST/HST [Goods and Services Tax/ harmonized sales tax] also applies on the fair market value of any goods or services you buy using digital currency.”33

  1. Trade inCryptocurrencies

As noted above, digital currency is characterized as a commodity under Canadian law. Thus, according to the Financial Consumer Agency, “[w]hen you file your taxes you must report any gains or losses from selling or buying digital currencies.”34 Any resulting gains or losses “could be taxable income or capital for the taxpayer.”35 The CRA has published a bulletin36 to “provide information that can help in determining whether transactions are income or capital in nature.”37 The CRA has also recently published an online guide for cryptocurrency users and tax professionals.38 According to lawyers from the law firm Gowling WLG,

[i]n general terms, where a taxpayer does not engage in the business of trading in cryptocurrency (i.e., the taxpayer acquires such property for a long-term growth), any gain or loss generated from the disposition of cryptocurrency should be treated as on account of capital. However, where a taxpayer engages in the business of trading or investing in cryptocurrency, gains or losses therefrom should be treated as being on account of income. The cost to the taxpayer of property received in exchange for cryptocurrency (for example, another type of cryptocurrency) should be equal to the value of the cryptocurrency given up as consideration.39

The law firm also notes that “it is possible that a trader in cryptocurrency would also be required to collect GST/HST (and QST [Quebec Sales Tax]) on their supplies, but the CRA has not expressed a clear view on this point.”40

  1. MiningCryptocurrencies

Mining of cryptocurrencies can be undertaken for profit (as a business) or as a personal hobby (which is nontaxable).41 According to the CRA,

[t]he income tax treatment for cryptocurrency miners is different depending on whether their mining activities are a personal activity (a hobby) or a business activity. This is decided case by case. A hobby is generally undertaken for pleasure, entertainment or enjoyment, rather than for business reasons. But if a hobby is pursued in a sufficiently commercial and businesslike way, it can be considered a business activity and will be taxed as such.42

According to the lawyers from Gowling WLG,

[i]f the taxpayer mines in a commercial manner, the income from that business must be included in the taxpayer’s income for the year. Such income will be determined with reference to the value of the taxpayer’s inventory at the end of the year, established pursuant to the rules in section 10 of the ITA and Part XVIII of the Regulations regarding valuing inventory.43

  1. Custodianship of Cryptocurrencies by Financial Institutions

According to CSA Staff Notice 46-307, “cryptocurrency offerings can provide new opportunities for businesses to raise capital and for investors to access a broader range of investments. However, they can also raise investor protection concerns, due to issues around volatility, transparency, valuation, custody and liquidity, as well as the use of unregulated cryptocurrency exchanges.”44 The notice states that fintech businesses, when establishing a crypto currency investment fund, should consider the following:

  1. Custody: Securities legislation of the jurisdictions of Canada generally require that all portfolio assets of an investment fund be held by one custodian that meets certain prescribed requirements. We expect a custodian to have expertise that is relevant to holding cryptocurrencies. For example, it should have experience with hot and cold storage, security measures to keep cryptocurrencies protected from theft and the ability to segregate the cryptocurrencies from other holdings as needed.45
  1. Regulation of Cryptocurrencies as Financial Securities

CSA Staff Notice 46-307 Cryptocurrency Offerings “outlines how securities law requirements may apply to initial coin offerings (ICOs), initial token offerings (ITOs), cryptocurrency investment funds and the cryptocurrency exchanges trading these products.”46

  1. Cryptocurrency Exchanges

The first part of the notice looks at the nature of cyptocurrency exchanges and possible requirements that apply. It states as follows:

A cryptocurrency exchange that offers cryptocurrencies that are securities must determine whether it is a marketplace. Marketplaces are required to comply with the rules governing exchanges or alternative trading systems. If an exchange is doing business in a jurisdiction of Canada, it must apply to that jurisdiction’s securities regulatory authority for recognition or an exemption from recognition. To date, no cryptocurrency exchange has been recognized in any jurisdiction of Canada or exempted from recognition. Allowing coins/tokens that are securities issued as part of an ICO/ITO to trade on these cryptocurrency exchanges may also place the business issuing the coins/tokens offside

securities laws. For example, the resale of coins/tokens that are securities will be subject to restrictions on secondary trading.47

  1. Treatment of Coin/Token Offerings

The second part of the notice looks at coin/token offerings and the circumstances under which they would be treated as securities. It states that

[s]taff is aware of businesses marketing their coins/tokens as software products, taking the position that the coins/tokens are not subject to securities laws. However, in many cases, when the totality of the offering or arrangement is considered, the coins/tokens should properly be considered securities. In assessing whether or not securities laws apply, we will consider substance over form.

Every ICO/ITO is unique and must be assessed on its own characteristics. For example, if an individual purchases coins/tokens that allow him/her to play video games on a platform, it is possible that securities may not be involved. However, if an individual purchases coins/tokens whose value is tied to the future profits or success of a business, these will likely be considered securities. We have received numerous inquiries from fintech businesses and their legal counsel relating to ICOs/ITOs. With the offerings that we have reviewed to date, we have in many instances found that the coins/tokens in question constitute securities for the purposes of securities laws, including because they are investment contracts. In arriving at this conclusion, we have considered the relevant case law,{6} which requires an assessment of the economic realities of a transaction and a purposive interpretation with the objective of investor protection in mind.48

  1. Applicable Securities Legislation Requirements

The CSA states that cryptocurrency offerings, including ICOs and ITOs, “may involve an offering of securities and therefore may trigger prospectus or registration requirements under applicable securities laws.”49 The requirements are outlined as follows:

  1. Businesses completing ICOs/ITOs may be trading in securities for a business purpose (referred to as the “business trigger”), therefore requiring dealer registration or an exemption from the dealer registration requirement. Whether or not an activity meets the business trigger is facts specific.
  2. Businesses completing ICOs/ITOs may be trading in securities for a business purpose (referred to as the “business trigger”), therefore requiring dealer registration or an exemption from the dealer registration requirement. Whether or not an activity meets the business trigger is facts specific.50
  1. Treatment of Cryptocurrency Investment Funds

The CSA notice also includes the following non-exhaustive list of matters fintech businesses should consider when looking to establish cryptocurrency investment funds:

  1. Retail investors: In certain jurisdictions of Canada, the OM prospectus exemption cannot be used by investment funds to distribute securities to investors.{10} Therefore, if investors in the investment fund will include retail investors, businesses will need to consider prospectus requirements, applicable investment fund rules and whether the investment is suitable.
  1. Cryptocurrency exchanges: Due diligence must be completed on any cryptocurrency exchange that the investment fund uses to purchase or sell cryptocurrencies for its portfolio, including on whether it is regulated in any way and the cryptocurrency exchange’s policies and procedures for identity verification, anti-money laundering, counter-terrorist financing and recordkeeping. Businesses should be prepared to discuss with staff how trading volumes on the cryptocurrency exchanges that the investment fund intends to use may affect the ability to buy and sell cryptocurrencies and to fund redemption requests.
  1. Registration: Businesses must consider appropriate registration categories in respect of the investment fund, including dealer, adviser and/or investment fund manager.
  1. Valuation: How will cryptocurrencies in the investment fund’s portfolio be valued? How will securities of the investment fund be valued? Will one or multiple cryptocurrency exchange(s) be used; and how will such exchange(s) be selected? Will there be an independent audit of the investment fund’s valuation?
  1. Custody: Securities legislation of the jurisdictions of Canada generally require that all portfolio assets of an investment fund be held by one custodian that meets certain prescribed requirements. We expect a custodian to have expertise that is relevant to holding cryptocurrencies. For example, it should have experience with hot and cold storage, security measures to keep cryptocurrencies protected from theft and the ability to segregate the cryptocurrencies from other holdings as needed.51
  1. Further Guidance on Token Offerings

CSA Staff Notice 46-308 Securities Law Implications for Offerings of Tokens“provides businesses that are considering offering digital tokens to the public with additional guidance on when securities may be involved and as to how securities regulation may apply to an ICO.”52 It provides particular guidance on the offering of tokens, including ones commonly known as “utility tokens.” The first part of the notice sets out the purpose and background behind the published guidance. It states that,

[s]ince SN 46-307 was published, staff have engaged with numerous businesses wishing to complete offerings of tokens and have found that most of these offerings have involved securities. As part of this engagement with businesses, we have received various inquiries relating to offerings of tokens referred to as “utility tokens”. “Utility token” is an industry term often used to refer to a token that has one or more specific functions, such as allowing its holder to access or purchase services or assets based on blockchain technology. We have seen many businesses offering tokens to raise capital for the development of their software, online platform or application. In many of these cases, the offering will involve securities despite the fact that the tokens have one or more utility functions.53

The notice then goes on to provide information on when an offering of tokens may or may not involve an offering of securities in light of the definition of “security,” stating that,

[a]s we indicated in SN 46-307, every offering is unique and must be assessed on its own characteristics. An offering of tokens may involve the distribution of securities, including because:

  • the offering involves the distribution of an investment contract; and/or
  • the offering and/or the tokens issued are securities under one or more of the other enumerated branches of the definition of security or may be a security that is not covered by the non-exclusive list of enumerated categories of securities.

In determining whether or not an investment contract exists, the case law endorses a purposive interpretation that includes considering the objective of investor protection. This is especially important for businesses to consider in the context of offerings of tokens where the risk of loss to investors can be high. Businesses and their professional advisors should consider and apply the case law interpreting the term “investment contract”{1}, including considering whether the offering involves:

  1. An investment of money
  1. In a common enterprise
  1. With the expectation of profit
  1. To come significantly from the efforts of others

In analyzing whether an offering of tokens involves an investment contract, businesses and their professional advisors should assess not only the technical characteristics of the token itself, but the economic realities of the offering as a whole, with a focus on substance over form.54

The notice then provides “examples of situations and their possible implication on one or more of the elements of an investment contract,” but cautions that they are intended to be illustrative

and not an exhaustive or determinative “on its own of whether or not a security exists.”55 The notice states that

[it is possible that an offering of tokens may be viewed as involving, or not involving, a security even with the existence, or absence, of one or more of the characteristics listed below. As such, businesses and their professional advisors should complete a meaningful analysis based on the unique characteristics of their offering of tokens and should not use the following table to complete a mechanical “tick the box” exercise.56

The notice also discusses “token offerings that are structured in multiple steps.”57 On the question of enforcement and compliance with securities legislation, the CSA provides the following guidance:

Staff are conducting active surveillance of coin and token offerings activity to identify past, ongoing and potential future violations of securities laws or conduct in the capital markets that is contrary to the public interest. CSA members have taken and intend to continue taking regulatory and/or enforcement action against businesses that do not comply with securities laws.

In order to avoid costly regulatory surprises, we encourage businesses with proposed offerings of tokens to consult qualified securities legal counsel in their local jurisdiction about the potential application of, and possible approaches required to comply with, securities legislation. As trends in the cryptocurrency industry are evolving quickly, we encourage businesses seeking flexible approaches to compliance with securities laws to contact their local securities regulatory authority to discuss their project at the contact information below. When contacting their local securities regulatory authority, businesses should be ready to provide a draft whitepaper, a business plan or a detailed description of their proposed offering. We may also ask for copies of promotional materials in connection with the offering, and a description of the promotional activities and marketing efforts in respect of the offering, as well as information on the corporate structure and principals involved. We remind businesses to consider securities law requirements that may apply to their activities, regardless of where investors are located. A Canadian securities regulatory authority may have jurisdiction over trades to investors outside of that jurisdiction where there is a real and substantial connection between the transaction and that jurisdiction.58

  1. CSA Regulatory Sandbox

The CSA Regulatory Sandbox is an initiative of the CSA “to support fintech businesses seeking to offer innovative products, services and applications in Canada.” According to the CSA notice,

[i]t allows firms to register and/or obtain exemptive relief from securities law requirements, under a faster and more flexible process than through a standard application, in order to test their products, services and applications throughout the Canadian market on a time-limited basis. Applications to the CSA Regulatory Sandbox are analyzed on a case-by-case basis.59

  1. Treatment of Cryptoassets Not Considered Securities

Apart from provincial level laws and regulations pertaining to securities, virtual currencies are also subject to the provincial-level consumer protection laws that are of general application. These laws may include provisions on cooling off periods/right to cancel, unsolicited goods, and misrepresentation/unfair business practices.60 According to one law firm,

[t]okens issued on functional networks with established, redeemable values may be analogized to gift cards. Transactions with such tokens may fall under the realm of consumer contracts regulated by the various provincial consumer protection agencies across Canada. For example, the statutes and regulations enforced by these agencies may impose implied legal warranties on the sale or redemption of tokens.61

  1. Distinctions in Treatment of Different Categories of Cryptocurrencies

No other guidance with respect to the treatment of different categories of cryptocurrencies or assets was located.


1 Conrad Druzeta et al., Canada, in BLOCKCHAIN & CRYPTOCURRENCY REGULATION 2019 (Josias Dewey ed., Global Legal Insights, 2019), Source Link, archived at Parent Source.
2 Id.
3 Digital Currency, FINANCIAL CONSUMER AGENCY OF CANADA (FCAC), Source Link (last updated Jan. 19, 2018), archived at parent source.
4 Id. 5 Id.
6 Currency Act, R.S.C., 1985, c. C-52, Source Link, archived at parent source.
7 Digital Currency, FCAC, supra note 3; Currency Act § 8.
8 Druzeta et al, supra note 1.
9 Overview, CANADIAN SECURITIES ADMINISTRATORS (CSA) Source Link (last updated Jan. 19, 2018), archived at Parent Source.
10 Druzeta et al., supra note 1.
11 CSA Staff Notice 46-307 Cryptocurrency Offerings (Aug. 24, 2017), Source Link, archived at parent source.
12 Press Release, CSA, Canadian Securities Regulators Outline Securities Law Requirements that May Apply to Cryptocurrency Offerings (Aug. 24, 2017), Source Link, archived at parent source.
13 CSA Staff Notice 46-308 Securities Law Implications for Offerings of Tokens (June 11, 2018), Source Link, archived at parent source.
14 Allan Goodman & Michael Partridge, Cryptocurrency in Canada, PRACTICAL LAW CANADA (Practice Note w- 013-8891, 2018), Source Link, archived at parent source.
15 Id.
16 Bill C-31, An Act to Implement Certain Provisions of the Budget Tabled in Parliament on February 11, 2014, and Other Measures, Second Session, Forty-first Parliament, 62-63 Elizabeth II, 2013-2014, Statutes of Canada 2014 Ch. 20, Source Link, archived at parent source.
17 Id. See also Tariq Ahmad, Canada: Canada Passes Law Regulating Virtual Currencies as “Money Service Businesses,” GLOBAL LEGAL MONITOR (July 9, 2014), Source Link, archived at parent source.
18 Christine Duhaime, Canada Implements World’s First National National Digital Currency Law; Regulates New Financial Technology Transactions, DUHAIME LAW (June 22, 2014), Source Link, archived at Parent Source.
19 Bill C-31, § 255(2). 20 Id. § 258. 21 Duhaime, supra note 18.
22 Corin Faife, Canada Is Gearing Up to Regulate Cryptocurrency, MOTHERBOARD (Mar. 20, 2018), Source Link, archived at parent source.
23 Id. 24 Id.25 Id.
26 Mariam Al-Shikarchy et al., Gowling WLG, Canadian Taxation of Cryptocurrency . . . So Far, LEXOLOGY (Nov. 14, 2017), Source Link(by subscription), archived at parent source.
27 Digital Currency, CANADA REVENUE AGENCY (CRA), Source Link (last updated Mar. 8, 2019), archived at parent source.
28 Guide for Cryptocurrency Users and Tax Professionals, CRA, Source Link (last updated Mar. 8, 2019), archived at parent source.
29 Id. 30 Digital Currency, FCAC, supra note 3.
31 What You Should Know about Digital Currency, CRA, Source Link(last updated Mar. 17, 2015), archived at parent source.
32 Digital Currency, CRA, supra note 27. 33 Digital Currency, FCAC, supra note 34 Id. 35 What You Should Know about Digital Currency, supra note 31.
36 CRA, Interpretation Bulletin IT-479R, Transactions in Securities, Source Link, archived at parent source.
37 What you Should Know about Digital Currency, supra note 31.
38 Guide for Cryptocurrency Users and Tax Professionals, supra note 28.
39 Al-Shikarchy et al., supra note 26. 40 Id.
41 Cryptocurrencies and Tax: Five Things Every Canadian Needs to Know, WILDEBOER DELLELCE (Dec. 12, 2017), Source Link, archived at parent source.
42 Guide for Cryptocurrency Users and Tax Professionals, supra note 28.
43 Al-Shikarchy et al., supra note 26.
44 CSA Staff Notice 46-307 Cryptocurrency Offerings, supra note 11. 45 Id.
46 Press Release, CSA, supra note 12.
47 CSA Staff Notice 46-307 Cryptocurrency Offerings, supra 11. 48 Id.
49 CSA Reinforces Position that Securities Laws Apply to Cryptocurrency Offerings, Confirms Regulatory Scrutiny for Industry Participants, ΜCMILLAN (2018), Source Link, archived at parent source.
50 CSA Staff Notice 46-307 Cryptocurrency Offerings, supra 11. 51 Id.
52 ONTARIO SECURITIES COMMISSION, TAKING CAUTION: FINANCIAL CONSUMERS AND THE CRYPTOASSET SECTOR 6 (June 28, 2018), Source Link, archived at parent Source.
53 CSA Staff Notice 46-308 Securities Law Implications for Offerings of Tokens, supra note 13. 54 Id. 55 Id. 56 Id.
57 CSA Staff Publish Follow-up Guidance on Token Offerings, LEXOLOGY (July 2 2018), Source Link (by subscription), archived at parent source.
58 CSA Staff Notice 46-308 Securities Law Implications for Offerings of Tokens, supra note 13. 59 Id.
60 Mathew Burgoyne, Canadian Provincial Bitcoin Law: It’s All About Protecting the Consumer, COINDESK.COM (Dec. 24, 2013), Source Link, archived at parent source.
61 Goodman & Partridge, supra note 14, at 12-13.

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Clark

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