Yes I think so as well. Last month Shakepay, a Canadian exchange registered with FINTRAC discontinued their Shakepay Earn program where they offered 4% APR paid monthly in Bitcoin on all cash balances up to $1k. Your money was not locked-in or rehypothiecated. There was no reason given why the program was discontinued.

Operation Chokepoint 2.0 … the closing down of on and off-ramps from fiat to bitcoin and bitcoin to fiat? “Then they fight you.”