I think at the moment the legal status of Bitcoin is unclear. You run into this minefield of legal terms that have very specific meanings (that may exclude bitcoin). But on the other hand, countries around the world have agreed to crack down on money laundering and terrorist financing.

Bitcoin may not be a "Foreign Currency" because it is not backed by any world government.

Bitcoin may not be a "Virtual currency" (Banned in China for the purchase or real goods) because is is not backed by any one issuer that can provide virtual goods and services, and is not pegged to a specific exchange rate.

Bitcoin may not be a "commodity" (what most exchanges treat it as) because it has no inherent value.

Bitcoin may not be a "security" (Subject to much more regulation than a commodity) because it acts more like a commodity.

That said, bitcoin users may have trouble with reporting requirements if their activities are considered a Money Services business. Just the act of relaying transactions on the network may subject you to reporting requirements you can't meet because the blockchain deals only with annonymized information. Adding sender information to the blockchain would be in violation of privacy laws because the information is public (and it would bloat the blockchain). That said, I am not convinced the Enabling legislation and regulations are actually that far-reaching. I am in the process of drafting a letter to FINTRAC asking for clarification.