Division 19 would apply to businesses that deal in virtual currencies, such as virtual currency exchanges, and not to retail businesses that accept virtual currencies as a method of payment.
if your business model is a FIAT<->BTC touching exchange, then your a MSB.. and you need a licence.
if your business model is not about moving FIAT person to person.. and is just a bitcoin store, a game, service etc.. then dont worry
it's still all about the fiat. as that is their jurisdiction (canadian dollars is their property)
Just for clarity, does the FIAT <-> BTC touching exchange model apply to average businesses/personal conversions of Bitcoin<->FIAT or only to businesses whose business model depends on it?
For example,
Would a business using BitPay's Bitcoin->Bank service be needing a license OR
Would a person converting Bitcoin to CAD be needing a license?