Who must register as an MSB
Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), a person or entity that carries on a money services business in Canada must register with FINTRAC before it starts operating. This applies even if you also hold a provincial licence. Foreign MSBs that direct services at people in Canada must register too.
The regulated activities include:
- foreign exchange dealing
- remitting or transmitting funds
- issuing or redeeming money orders and traveller's cheques
- dealing in virtual currency
- operating a crowdfunding platform
- armoured car services and cheque cashing
- acting as a private ATM acquirer
Registration is not a licence, and FINTRAC does not endorse registered businesses. There is no registration fee, and the registry of MSBs is public.
What you need before you apply
Gather the information first. An incomplete package is the most common reason for delays. You will generally need:
- your incorporation documents and business details
- Canadian bank account details
- the name of your compliance officer
- details of owners and senior management
- your employee count and locations
- estimated transaction volumes
- details of any agents or mandataries you use
Criminal record checks
Criminal record checks are required for the CEO, the president, directors and anyone who owns or controls 20% or more of the business. Each check must be issued within the six months before you apply. If a document is not in English or French, you need a certified translation.
How the process works
- Complete the pre-registration form on FINTRAC's website.
- Submit the full registration application with supporting documents.
- Respond to any request for clarification from FINTRAC.
- Receive the decision and appear in the public MSB registry.
| Stage | What happens | Time limit |
|---|---|---|
| Application | You submit a complete package | Before you operate |
| Review | FINTRAC assesses the package | Most complete applications within about three months |
| Clarification | FINTRAC may ask for more information | 30 days to respond |
| Registration | Valid for two years | Renew before expiry |
FINTRAC says that the majority of complete applications are processed within three months. The clock starts when it has a complete package, so do not treat that as a guaranteed date. If you do not answer a clarification request in time, your application can be refused.
Renewal and changes
A registration is valid for two years. Renew before it expires. Failing to renew can lead to administrative monetary penalties or criminal charges. You must also tell FINTRAC about changes to your registration information within 30 days, and tell it within 30 days if you stop providing MSB services.
Penalties for operating unregistered
Knowingly breaking the registration requirement is a criminal offence. On summary conviction the maximum is a fine of up to $2,500,000, up to two years less a day in jail, or both. On indictment it is a fine of up to $5,000,000, up to five years in jail, or both.
Separately, amendments that received Royal Assent on March 26, 2026 created a new administrative penalty framework, with maximum penalties up to 40 times the previous limits for violations on or after that date. The framework also adds compliance orders and compliance agreements, and lets FINTRAC consider a business's ability to pay. Read the current rules on FINTRAC's website for the exact amounts.
What happens after you register
Registration is the start of your obligations. You must run a compliance program with a compliance officer, written policies and procedures, a risk assessment, training and a review of its effectiveness every two years. From March 26, 2026, the program must be reasonably designed, risk-based and effective. See our guide to FINTRAC compliance program requirements for the detail.
You must also report certain activity and keep records for at least five years. Reports include suspicious transactions as soon as practicable, cash transactions of $10,000 or more, large virtual currency transactions, electronic funds transfers and property of listed persons or entities.
Agents and mandataries
Since October 1, 2025, MSBs must verify agents or mandataries before engaging them, run criminal record checks and re-verify them within 30 days after the second anniversary. Agents already in place must comply by October 1, 2027.
Common mistakes to avoid
- Starting to move money for customers before the registration is in place.
- Submitting criminal record checks older than six months.
- Naming a compliance officer who does not understand the business or has no time for the role.
- Using generic policies that do not reflect your products, customers and countries served.
- Missing the 30-day deadline to answer FINTRAC's questions or to report a change.
A realistic timeline matters too. Allow time to prepare documents, obtain the checks, wait for review and open banking relationships. Banks often want to see your registration and compliance program before they will serve an MSB, so plan your launch around those steps and not around a single date.
Getting help
You can complete the application yourself. Many founders prefer help because the compliance program has to be ready on day one. Our FINTRAC compliance service covers registration and program documents. If your corporation is not yet set up, see business registration, or contact us to talk through your situation.
Official sources: FINTRAC money services businesses, how to register and responding to clarification requests.