Please note that any bank or EMI that is located in any country that enforces CRS can report your transactions to Canadian authorities. And the list of countries that do not enforce CRS is becoming narrower and narrower... (from the more reputable perhaps Monte Negro, Philippines, Paraguay, if I recall well).
Why not to call them EMI? They are licensed in Puerto Rico as an International︀ Financial Entity, it seems to me like an EMI-type licence. Or am I wrong? (BTW,︁ at their webpage they claim that they have “banking license” – it is a false︂ claim, obviously.)
(Not to be misunderstood: I do not claim that they are bad guys,︃ it is possible that they are serving well... I just went through their webpage.)