Money services business (MSB) registration (Canada)
Money services business (MSB) registration in Canada is issued by FINTRAC under the PCMLTFA. It covers money remittance, foreign exchange, virtual currency dealing, and crowdfunding. Registration requires zero statutory capital and zero FINTRAC fees. Applicants must complete pre-registration, provide criminal record checks for directors and 20%+ owners, and establish a full AML/CTF compliance program. Processing typically takes around three months for complete applications.
At a glance
| Official name | Money services business (MSB) registration (covers foreign exchange dealing, money transferring, virtual currency dealing, crowdfunding platforms and related services; a separate foreign-MSB registration applies to businesses without a place of business in Canada that direct services at Canadians)1 |
|---|---|
| Local name | Inscription comme entreprise de services monétaires (ESM) |
| Also known as | MSB · ESM · FMSB · FINTRAC MSB registration · Canadian MSB registration · Canada MSB |
| Market names to check | MSB licence: An MSB is registered with FINTRAC, not licensed; the registration is a compliance listing |
| Issued by | Financial Transactions and Reports Analysis Centre of Canada |
| Jurisdiction | Canada |
| Licence family | Money transmitter / money services business (MSB) |
| Legal basis | Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA, S.C. 2000, c. 17), ss. 5(h), 5(h.1), 11.1, 11.11, 11.12, 11.13, 11.152 Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR, SOR/2002-184), ss. 9.6, 37.1, 1563 Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (PCMLTFRR, SOR/2007-121), ss. 6.02, 6.034 Retail Payment Activities Act (RPAA, S.C. 2021, c. 23, s. 177) administered by the Bank of Canada, ss. 24, 48 (payment service provider registration alongside FINTRAC's MSB regime)5 |
| Passporting | Domestic only: No passporting. Registration is valid across all 10 Canadian provinces and 3 territories for federal AML/CTF purposes under the PCMLTFA. However, individual provinces may impose separate provincial registration or licensing (such as Quebec's Money Services Businesses Act administered by Revenu Québec / AMF, or provincial securities regulator requirements for crypto trading platforms). Foreign MSBs registered with FINTRAC can serve Canadian residents cross-border without a physical presence in Canada.1 |
| Minimum capital | CAD 06 |
| Application fee | CAD 0 (no fee)6 |
| Annual fee | CAD 0 (no fee)6 |
| Statutory decision time | No fixed statutory maximum found; FINTRAC states most complete applications are processed within a target window (see observed)6 |
| Public register | official register7 |
| Current holders | 40597 |
What it lets you do, and where
What does a Canadian MSB registration let you do, and where can you serve clients?
A Canadian registration covers the MSB activities listed in PCMLTFA s. 5(h): foreign exchange dealing, remitting or transmitting funds, and dealing in virtual currencies. FINTRAC MSB guidance confirms federal registration applies nationwide, across all Canadian provinces and territories. Separately, the Revenu Québec Money-Services Businesses Act (CQLR c. E-12.000001) requires anyone operating a money-services business to hold a licence.222321
Activities it covers
| Money remittance | Receiving funds from a payer solely to transfer them to a payee or another provider, without opening payment accounts. |
|---|---|
| Currency exchange | Buying and selling foreign currency for customers, in cash or electronically, as a bureau de change or FX service. |
| Virtual asset exchange (FATF) | Exchanging virtual assets for fiat currency or for other virtual assets as a business, as defined in the FATF glossary. |
| Virtual asset transfer (FATF) | Conducting transactions that move virtual assets between addresses or accounts on behalf of another person. |
| Crowdfunding services | Matching business funding interests of investors and project owners through a platform, by facilitating loans or placing securities. |
Where it is valid
Do you need it, and is Canada the right choice?
What is a Canadian Money Services Business (MSB) registration and do you actually need one?
A Canadian MSB registration is a federal registration with FINTRAC under the PCMLTFA. Under s. 11.1, every person or entity referred to in paragraph 5(h) or (h.1) must register with FINTRAC. It is not a licence, government endorsement, or safety guarantee. Operating without registration carries criminal penalties under s. 74 of up to $5,000,000 or 5 years imprisonment on indictment.24257
Is a Canadian MSB registration right for your business model, and when is Canada the wrong choice?
The Retail Payment Activities Act (S.C. 2021, c. 23) requires mandatory PSP registration and fund-safeguarding for end-user funds holding. On August 6, 2024, CSA and CIRO announced they do not intend to continue the interim restricted-dealer approach. The CIRO entrance fee for an Investment Dealer Crypto Asset Trading Platform is CAD 40,000.262716
Is a Canadian MSB a licence or a registration, what does it let you do?
An MSB with FINTRAC in Canada is a registration, not a licence. FINTRAC's official register explicitly warns that registration does not indicate FINTRAC endorses or licenses the business. AML Incubator analysis states there is no such thing as an MSB license in Canada, only registration. Separately, under the Revenu Québec Money Services Businesses Act (CQLR c. E-12.000001), a person or entity operating an MSB for remuneration must hold a provincial licence.72823
Do you need a separate MSB licence for Quebec on top of FINTRAC?
Quebec MSB licensing applies to online and web-based services directed at Quebec persons. Section 5 of the Money-Services Businesses Act (CQLR c. E-12.000001) applies even to MSBs without a head office or establishment in Québec. The fee regulation sets the official fees.293023
What it really takes
How much capital do you really need for a Canadian MSB registration?
A FINTRAC-only money services business in Canada has no statutory minimum capital requirement. Crassula's setup guide estimates a typical first-year all-in cost of CAD 100,000 to 300,000. Under RPAA s. 20(1), end-user funds must be held in a dedicated trust account, in a prescribed account or manner, or in a dedicated account covered by insurance or a guarantee.162131
Who do you have to hire for a Canadian MSB, and where must they be based?
PCMLTFR s. 156(1)(a) mandates appointment of a compliance officer responsible for implementing the AML/CTF program. PCMLTFA s. 11.12(1)(c.1) requires Foreign MSBs to provide the name and address for service of a person who resides in Canada. eCompanies Canada quotes an annual fee of USD $4,000 for its FINTRAC Representative for Service offering.323334
The statutory list of what an MSB registration application must contain is defined in Schedule 1 of the PCMLTFRR (SOR/2007-121). Under s. 4, the information must be submitted according to FINTRAC's guidelines: electronically where technically capable, otherwise by telephone. The FINTRAC registration checklist details operational document requirements and criminal record check formatting.14116
Requirements
| Requirement | What is needed | Legal reference |
|---|---|---|
| Capital and people assessed | ||
| Minimum capital | CAD 06 | |
| Ongoing own funds | No ongoing own-funds, capital-adequacy or solvency ratio requirements apply to FINTRAC-registered MSBs. Ongoing supervision is conduct and AML/CTF compliance-based (maintaining a compliance program, KYC, transaction reporting, and biennial independent reviews). Note that entities providing retail payment activities in Canada may be subject to fund-safeguarding requirements under the Bank of Canada's Retail Payment Activities Act (RPAA), which requires holding end-user funds in trust at a prudentially regulated financial institution or backed by insurance/guarantee.1 | |
| Who is assessed | FINTRAC assesses the criminal eligibility of owners, leaders, and agents. Applicants must submit criminal record checks (issued within 6 months by competent authorities in the individual's country of residence) for the CEO, president, all directors, and each person or entity owning or controlling, directly or indirectly, 20% or more of the entity or its shares, as well as sole proprietors. Individuals convicted of money laundering, terrorist financing, organized crime, fraud, drug trafficking, or listed under terrorist/sanctions legislation are legally ineligible to register, own, direct, or act as an agent for an MSB.8 | PCMLTFA s. 11.11 |
| Substance and people | ||
| Compliance officer appointment | Reporting entities must appoint a compliance officer responsible for implementing and overseeing the AML/CTF compliance program. The officer must have the necessary authority and direct access to senior management and the board of directors, and should ideally be independent from front-line transaction processing.9 | PCMLTFR s. 156(1)(a) |
| Compliance policies and procedures | MSBs must develop and apply written compliance policies and procedures that are kept up to date and, in the case of an entity, approved by a senior officer. These policies govern KYC, transaction monitoring, reporting, record keeping, and ministerial directives.9 | PCMLTFR s. 156(1)(b) |
| Documented risk assessment | MSBs must conduct and document an assessment of the risks of money laundering, terrorist financing, and sanctions evasion occurring in the course of their activities, assessing products, services, delivery channels, geographic locations, and client types, and implementing enhanced measures for high-risk scenarios.9 | PCMLTFR s. 156(1)(c) |
| Ongoing compliance training program | MSBs must develop and maintain a written, ongoing compliance training program and documented training plan for all employees, agents, mandataries, and other authorized representatives who deal with clients or transactions.9 | PCMLTFR s. 156(1)(d) |
| Two-year effectiveness review (independent audit) | MSBs must institute and document a plan for reviewing the compliance program to test its effectiveness, and carry out this review every two years at a minimum. The review must test policies, procedures, risk assessment, and training, and can be conducted by an internal or external auditor.9 | PCMLTFR s. 156(1)(e) |
| Agent and mandatary oversight and background checks | 2025), MSBs engaging agents or mandataries must verify their eligibility and obtain and review criminal record checks for sole proprietors, or the CEO, president, directors, and 20%+ owners of agent entities, both prior to engagement and within 30 days of each two-year anniversary.1 | PCMLTFA s. 9.9 |
| Canadian representative for service (Foreign MSBs) | A Foreign MSB (FMSB) with no place of business in Canada must appoint and maintain a representative for service who is an individual residing in Canada, authorized to receive official notices and inquiries from FINTRAC.6 | PCMLTFA s. 11.12(1.1) |
| Place of business in Canada (Domestic MSBs) | A domestic MSB must maintain a place of business in Canada, meaning it is incorporated in Canada, has a physical location in Canada, or has employees, agents, or branches operating in Canada.1 | PCMLTFA s. 5(h) |
| Conditions to keep the licence | ||
| Biennial renewal of registration | Under FINTRAC registration rules, MSB registration is valid for two years. Registered entities must submit a renewal application before the expiry date to maintain Registered status; failure to renew results in Expired status, making further operations unlawful.10 | |
| 30-day change notification obligation | MSBs must inform FINTRAC of any changes to registration information (including addresses, contact persons, agents, services, or ownership structure) within 30 days by submitting the official Change form.10 | |
| Mandatory Canadian representative for service for Foreign MSBs | Foreign MSBs must maintain a Canadian representative for service at all times and notify FINTRAC of any change to the representative's name or address within 30 days; failure to notify within 30 days results in mandatory revocation of registration.10 | |
| Prohibition on marketing registration as a licence or endorsement | FINTRAC registration is not an endorsement or licence. It is strictly prohibited and illegal to market or advertise a business as 'licensed by FINTRAC' or endorsed by FINTRAC or the Government of Canada.7 | |
| Mandatory transaction reporting | MSBs must submit prescribed transaction reports to FINTRAC: Suspicious Transaction Reports (STRs as soon as practicable), Large Cash Transaction Reports (LCTR, CAD 10,000+ within 15 days), Large Virtual Currency Transaction Reports (LVCTR, CAD 10,000+ within 5 working days), Electronic Funds Transfer Reports (EFTR, CAD 10,000+ within 5 working days), and Terrorist Property Reports (TPR immediately).1 | |
| Record keeping and KYC verification | MSBs must verify client identity according to prescribed methods, keep client identification, transaction, and beneficial ownership records for at least 5 years, and comply with the Travel Rule for electronic funds and virtual currency transfers.1 | |
| Two-year compliance effectiveness review | MSBs must conduct an independent audit or review of their AML/CTF compliance program, policies, procedures, risk assessment, and training at least once every two years.9 | PCMLTFR s. 156(1)(e) |
| Cessation of activities notification | If an MSB ceases to provide money services business services, it must submit an official Cessation form to FINTRAC within 30 days of stopping operations.10 | |
The legal framework
| Level | Document | What it does here |
|---|---|---|
| Act | Proceeds of Crime (Money Laundering) and Terrorist Financing Act | Core federal governing statute: establishes FINTRAC, defines domestic and foreign MSBs (ss. 5(h), 5(h.1)), mandates registration (s. 11.1), sets ineligibility grounds (s. 11.11), registration procedure (s. 11.12), 30-day change notification (s. 11.13), renewal (s. 11.19), internal review (s. 11.3), Federal Court appeal (s. 11.4), compliance program duties (s. 9.6), and agent/mandatary vetting (ss. 9.9-9.93) |
| Secondary legislation | Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (SOR/2007-121) | Governs MSB registration mechanics, electronic filing (s. 4), registration and renewal contents (s. 5, Schedule 1), corporate existence/ownership documents (s. 6.02), 6-month validity window for criminal record checks (s. 6.03), renewal timetable (s. 6.1), and cessation notice (s. 6, Schedule 2) |
| Secondary legislation | Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (SOR/2002-184) | Comprehensive AML/CTF operating regulations: mandates 5-pillar compliance program (compliance officer, policies/procedures, risk assessment including sanctions evasion, ongoing training, biennial independent effectiveness review under s. 156), customer identification, and transaction record-keeping |
| Secondary legislation | Proceeds of Crime (Money Laundering) and Terrorist Financing Suspicious Transaction Reporting Regulations (SOR/2001-317) | Prescribes time, manner, and details for reporting suspicious transactions (STRs) to FINTRAC under section 7 of the PCMLTFA |
| Secondary legislation | Proceeds of Crime (Money Laundering) and Terrorist Financing Administrative Monetary Penalties Regulations (SOR/2007-292) | Classifies violations of PCMLTFA and regulations into minor, serious, and very serious categories and sets penalty ranges under s. 73.1 of the Act |
| Secondary legislation | Retail Payment Activities Regulations (SOR/2023-222) | Implements the RPAA: sets CAD 2,500 PSP registration application fee, annual supervisory assessment methodology, fund safeguarding mechanics, operational risk management standards, and incident reporting rules |
| Procedure law | Official Languages Act (R.S.C., 1985, c. 31 (4th Supp.)) | Guarantees the right of members of the public to communicate with and receive services from federal institutions including FINTRAC in English or French (ss. 21-22), ensuring bilingual application processing and correspondence |
| Procedure law | Federal Courts Act (R.S.C., 1985, c. F-7) | Governs statutory appeals under PCMLTFA s. 11.4 and applications for judicial review against federal boards, commissions, or tribunals under ss. 18 and 18.1 before the Federal Court |
| Forms | FINTRAC Online Registration Forms Pack | Prescribes electronic intake instruments: Pre-registration form (cmo7fwq0t00iayi0102lj14ej), formal MSB/FMSB Registration Form, Change Form, Renewal Form, and Cessation Form |
11 related regimes and guidance documents
| Level | Document | What it does here |
|---|---|---|
| Guidance | FINTRAC Guidance: Register your money services business or your foreign money services business | Administrative guidance setting out the 3-step registration process (pre-registration form, compliance officer interview/questionnaire, SDTS secure transfer), 15-day SDTS link expiry, document requirements, and 3-month target processing timeline |
| Guidance | FINTRAC Guidance: Compliance program requirements (Guide 4) | Comprehensive regulatory guidance detailing FINTRAC's expectations for establishing the five required elements of an AML/CTF compliance program under PCMLTFR s. 156 |
| Guidance | FINTRAC Guidance: Who is not eligible to register as a money services business or act as an agent or mandatary | Interprets statutory ineligibility criteria under PCMLTFA s. 11.11 and PCMLTFRR s. 3, criminal background check requirements, 6-month validity window, and certified translation rules |
| Guidance | FINTRAC Guidance: Foreign money services businesses | Specifies requirements for foreign entities directing services at persons in Canada without a physical Canadian place of business, including mandatory appointment of a Canadian resident representative for service |
| Guidance | FINTRAC Guidance: Answer clarification requests, Update, Renew or Cancel your registration | Details procedures for responding to 30-day clarification requests, submitting 30-day change notifications, completing biennial renewals, and submitting cessation forms |
| Related regime | Retail Payment Activities Act (S.C. 2021, c. 23, s. 177) | Parallel federal regime administered by Bank of Canada: requires PSPs performing retail payment activities to register under s. 23, safeguard end-user funds in trust/prescribed/segregated accounts under s. 20, obtain prior approval for change of control under s. 24, pass national security review under ss. 34/40, and conditions PSP registration on maintaining FINTRAC MSB registration under s. 48 |
| Related regime | Criminal Code (R.S.C., 1985, c. C-46) | Defines predicate offences and ineligibility criteria under PCMLTFA s. 11.11, including money laundering (s. 462.31), terrorist financing (ss. 83.02-83.04), criminal organization offences (ss. 467.11-467.13), and fraud (s. 380) |
| Related regime | United Nations Act (R.S.C., 1985, c. U-2) and Special Economic Measures Act (S.C. 1992, c. 17) | Enforces Canadian and international economic and financial sanctions, constituting mandatory grounds for ineligibility and revocation under PCMLTFA s. 11.11(1)(a) and (b.1) |
| Related regime | Freezing Assets of Corrupt Foreign Officials Act (S.C. 2011, c. 10) and Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law, S.C. 2017, c. 21) | Imposes sanctions against corrupt foreign officials and human rights violators, establishing mandatory grounds for ineligibility and revocation under PCMLTFA s. 11.11(1)(b.2) and (b.3) |
| Regional rules | Money-Services Businesses Act (Quebec, CQLR c. E-12.000001 / Loi sur les entreprises de services monétaires) | Quebec provincial statute administered by Revenu Québec: requires a separate provincial MSB licence for operating currency exchange, funds transfer, cheque cashing, traveller's cheque/money order issuance, or ATMs / crypto-ATMs in Quebec, with mandatory security clearances by the Sûreté du Québec |
| Regional rules | Charter of the French Language (Quebec, CQLR c. C-11 / Charte de la langue française) | Quebec quasi-constitutional language statute: requires communications with Quebec civil administration (Revenu Québec) and consumer agreements/contracts of adhesion in Quebec to be in French |
The procedure under the law
| Step | What the law says | Legal reference |
|---|---|---|
| How to file | Under section 4 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (SOR/2007-121), an applicant must give the information to the Centre, following the Centre's guidelines, electronically if they have the technical capability, or by telephone if they do not. FINTRAC's website states that the completed registration form and required information are sent to FINTRAC via a link from FINTRAC's Secure Document Transfer System or a Canada Post Connect message provided by a FINTRAC compliance officer.611 | Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (SOR/2007-121), s. 4 |
| Language | If a document referred to in PCMLTFA s. 11.12(1)(b) or (c) is in a language other than English or French, the application must include a translation into English or French attested by a certified translator recognised by a competent provincial/territorial or foreign body. FINTRAC requires a statement of certification or certificate of authenticity with the translator's stamp or membership number.6 | |
| What the application contains | Under section 4 of the Registration Regulations (SOR/2007-121), an applicant must send the Centre the information in a registration application referred to in section 11.12 of the Act, per Centre guidelines, electronically or by telephone. Schedule 1 (Sections 2, 5 and 6.01) lists the information for registration and renewal applications (Part A: identifying information, e.g. applicant's name and operating name). Schedule 2 covers cessation of activity.121361411 | Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), s. 11.12(1); Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations (SOR/2007-121), ss. 5, 6.02, 6.03, and Schedule 1 (Parts A to D) |
| Decision clock | There is no statutory decision deadline in these materials. FINTRAC says most complete applications are processed within three months from receipt of a complete application package; more complex ones may take longer. FINTRAC accepts only complete applications. Clarification requests must be answered within 30 days or FINTRAC may deny the application (s. 11.14). The secure transfer link expires after 15 days, closing the application. Registration takes effect only when FINTRAC adds you to the registry (s. 11.15); operating unregistered may lead to penalties or criminal charges.615 | |
| Fees set by law | FINTRAC charges no fee for money services business or foreign money services business registration. Registration is renewed every two years and the renewal fee is nil. The Proceeds of Crime (Money Laundering) and Terrorist Financing Registration Regulations set out application, renewal, change-notification and cessation-of-activity requirements but contain no fee provisions.616 | PCMLTFA contains no statutory fee-charging power for MSB registration; FINTRAC official policy under PCMLTFA s. 11.12 confirms zero application, registration, renewal, or amendment fees |
| Grounds for refusal | Under PCMLTFA s. 11.11(1), persons or entities are not eligible for registration with the Centre on listed grounds: terrorist/UN sanctions (a), Criminal Code listed entities (b), SEMA financial prohibitions (b.1), Magnitsky Law orders (b.2), corrupt foreign officials (b.3), convictions for ML/TF or listed offences (c), repeated/indictment convictions for fraud, drug, customs or tax offences (d), corporations with convicted directors/20% owners (e), unpaid penalties (e.1), evading penalties (e.2), or prescribed persons (f).15 | |
| Appeal | Yes. Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), within 30 days of receiving a denial or revocation, the applicant may apply in writing to the Director of the Centre for review (s. 11.3). The applicant may appeal the Director's decision to the Federal Court within 30 days after service (s. 11.4(1)). If the Director does not decide within 90 days, the applicant may appeal to the Federal Court within 30 days after that period expires (s. 11.4(2)).1718 | Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17), ss. 11.3, 11.4; Federal Courts Act (R.S.C. 1985, c. F-7), ss. 18.1, 28 |
| Validity | Registration with FINTRAC is valid for two years and must be renewed before its expiry date using the FINTRAC renewal form. A business that does not renew is shown as 'Expired' in the registry.10197 | |
| Change of control | FINTRAC processes most complete applications within three months of a complete package. Under the RPAA, a planned acquisition of control of a registered payment service provider requires a new application and registration before the acquisition takes effect. Criminal record checks must be issued no more than 6 months before review.2061 | |
| Reapplying after a refusal | None of the governing texts held for this licence (Proceeds of Crime (Money Laundering) and Terrorist Financing Act; Proceeds of Crime (Money Laundering) and Terrorist Financing Act; Retail Payment Activities Act; National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations; National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations) contains a provision on a waiting period before a new application after refusal or withdrawal. | |
| Serving other countries | One FINTRAC registration covers all of Canada, its ten provinces and three territories. Quebec additionally requires a provincial money-services business licence, issued by Revenu Québec. Passporting across states is an EU/EEA feature, not a Canadian one.21 |
How long it takes
How long does getting a Canadian MSB registration really take?
FINTRAC states the majority of complete applications are processed within three months of receipt of a complete package. Crassula reports an end-to-end timeline of 8 to 16 weeks, with FINTRAC processing taking three to six weeks. Renno & Co. reports about five to six months on managed files, or nine months or longer without experienced support. Substance Law notes requests for clarification are normal and prompt responses keep applications moving.6352136
There is no statutory decision deadline: PCMLTFA Part 1.1 sets no time limit or binding deadline for FINTRAC's initial registration decisions. FINTRAC's published service standard targets processing the majority of complete applications within 3 months. If FINTRAC requests clarifications, PCMLTFA s. 11.14 gives you 30 days to respond; otherwise FINTRAC may deny the application.637
What it costs
What does a Canadian MSB registration cost in total, first year and ongoing?
FINTRAC does not charge registration fees, so application and renewal cost CAD 0. C&G Regulatory Solutions prices the independent effectiveness review, required every two years, at CAD 5,000 to 15,000+. Crassula estimates a typical first-year all-in cost of CAD 100,000 to 300,000.63821
Approval odds and who can own it
What are the real approval odds for a Canadian MSB, and why do applications fail or get revoked?
FINTRAC's registry lists active, revoked and expired statuses, updated monthly. AML Incubator reports a 2026 crackdown revoking dozens of crypto-linked registrations, sometimes several in one day. Penalties include C$176,960,190 against Xeltox Enterprises Ltd. (Cryptomus) on October 22, 2025 (2,593 violations) and C$19,552,000 against Peken Global Ltd. (KuCoin) in September 2025; annual AMPs rose from 8 (2021) to 30 (2025). Under the March 2026 AMP framework the maximum is up to $20,000,000 per violation.739404142
Who can own and run a Canadian MSB, fit and proper, UBO, sanctions, and foreign founders?
PCMLTFA s. 11.11 establishes statutory ineligibility for individuals convicted of money laundering, terrorist financing, or serious offences. PCMLTFA s. 11.12(1)(c) mandates a record of criminal convictions for the CEO, president, directors, and 20%+ owners of an MSB entity. FINTRAC guidance defines a competent authority for submitting criminal record checks as any person or organization with legally delegated authority to issue them.43338
After you get the licence
What else will you need alongside a Canadian MSB registration?
Retail Payment Activities Act (S.C. 2021, c. 23) s. 29 mandates separate registration with the Bank of Canada accompanied by the prescribed application fee. BLG notes PSPs may also be required to register as MSBs. On August 6, 2024, CSA and CIRO announced they do not intend to continue the interim restricted-dealer approach, expecting platforms to pursue investment dealer registration and CIRO membership. Under CQLR c. E-12.000001, a money-services business must hold a Revenu Québec licence.262344
Will a Canadian MSB get a bank account and payment processing?
Banking research on Canadian MSBs identifies categories such as Schedule II banks, credit unions and specialty banks, but does not publicly name institutions. On May 2, 2024, FINTRAC publicly announced a CA $9,185,000 administrative monetary penalty on Toronto-Dominion (TD) Bank for five AML/CTF violations.4546
What does it take to keep a Canadian MSB registration, and what is changing?
PCMLTFR s. 156(1)(f) and (3) require instituting a review plan and carrying out a review to test compliance program effectiveness every two years. PCMLTFA s. 9.9 defines agent or mandatary as an agent or mandatary acting on behalf of an MSB to provide money services. Under the new framework in force from March 26, 2026, compliance agreements are mandatory for prescribed violations and require correcting deficiencies. C&G Regulatory Solutions breaks down independent AML effectiveness audit costs from $5,000 to $15,000+ CAD.32474138
Yes. PCMLTFA s. 11.3 lets you apply in writing to the Director of FINTRAC for review within 30 days. Under s. 11.4 you may then appeal to the Federal Court of Canada within 30 days of the Director's decision, or 90 days if the Director does not act. In Kabul Farms Inc. v. Canada, 2016 FCA 143, the Federal Court of Appeal confirmed appellate judicial review standards under the PCMLTFA.171848
A Canadian MSB registration is valid for two years, and a biennial renewal must be submitted before it expires. PCMLTFA s. 11.13(1) requires notifying FINTRAC within 30 days of becoming aware of a change, with form and manner prescribed by SOR/2007-121 s. 4.1037
Buying a company that already holds it
FINTRAC MSB registration is granted strictly to the specific legal entity and cannot be assigned, transferred, or sold to another entity. In a corporate acquisition executed through a share deal, the registered corporate entity retains its registration number and status, provided it notifies FINTRAC within 30 days and submits criminal record checks for new 20%+ controllers. An asset deal or transfer of operations to a different corporate vehicle requires the acquiring entity to complete pre-registration and submit a new MSB registration application.10
Notification only. Under the PCMLTFA and FINTRAC Registration Regulations, registered MSBs must keep their registration information up to date and notify FINTRAC of any change in ownership, control, directors, officers, contact persons, or representative for service within 30 days of the change. For any new person or entity acquiring, directly or indirectly, 20% or more ownership or control, a valid criminal record check issued within the preceding 6 months must be submitted. Failure to report changes within 30 days can result in administrative monetary penalties, criminal charges, or registration revocation. Note that under the Bank of Canada's Retail Payment Activities Act (RPAA s. 24), a payment service provider must submit a new registration application (re-registration) and receive approval before an acquisition of one-third or more of voting control closes, subject to a national-security review by the Minister of Finance (60 to 180+ days).10
Ready-made companies holding this licence: see verified positions.
MSB in other countries
| Country | Licence | Regulator | Min. capital | Application fee | Statutory time |
|---|---|---|---|---|---|
| Australia | Registration as a remittance service providerRegistration as a remittance service provider (remittance network provider or independent remittance dealer) | AUSTRAC | n/a | n/a | n/a |
| British Virgin Islands | Money Services Business Licence, Class A or Class BMoney Services Business Licence, Class A (money/electronic/mobile money transmission) or Class B (money orders, traveller's cheques, cheque cashing, currency exchange) | BVI FSC | n/a | n/a | n/a |
| Canada | Money services business (MSB) registrationMoney services business (MSB) registration (covers foreign exchange dealing, money transferring, virtual currency dealing, crowdfunding platforms and related services; a separate foreign-MSB registration applies to businesses without a place of business in Canada that direct services at Canadians) | FINTRAC | n/a | n/a | n/a |
| Dubai International Financial Centre (DIFC) | Money transmitter licenceFinancial Services Permission for Providing Money Services restricted to Money Transmission only (Category 4) | DFSA | n/a | USD 10,000 | n/a |
| Netherlands | Exchange institution licenceExchange institution licence (Vergunning wisselinstelling) | DNB | n/a | n/a | n/a |
| United States | Registration of Money Services Business (Form 107 / RMSB) | FinCEN | n/a | n/a | ~5.9 mo |
Values come from each licence's page, where every figure has its source.
Laws behind it
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act: S.C. 2000, c. 17
Getting this licence
Protegra handles this licence end to end: MSB registration in Canada: process, timeline and our fee.
Frequently asked questions
What is a Canadian Money Services Business (MSB) registration and do you actually need one?
A Canadian MSB registration is a federal registration with FINTRAC under the PCMLTFA.
How much capital do you really need for a Canadian MSB registration?
A FINTRAC-only money services business in Canada has no statutory minimum capital requirement.
How long does getting a Canadian MSB registration really take?
FINTRAC states the majority of complete applications are processed within three months of receipt of a complete package.
What does a Canadian MSB registration cost in total, first year and ongoing?
FINTRAC does not charge registration fees, so application and renewal cost CAD 0.
What are the real approval odds for a Canadian MSB, and why do applications fail or get revoked?
FINTRAC's registry lists active, revoked and expired statuses, updated monthly.
What does a Canadian MSB registration let you do, and where can you serve clients?
A Canadian registration covers the MSB activities listed in PCMLTFA s. 5(h): foreign exchange dealing, remitting or transmitting funds, and dealing in virtual currencies.
Will a Canadian MSB get a bank account and payment processing?
Banking research on Canadian MSBs identifies categories such as Schedule II banks, credit unions and specialty banks, but does not publicly name institutions.
Who do you have to hire for a Canadian MSB, and where must they be based?
PCMLTFR s. 156(1)(a) mandates appointment of a compliance officer responsible for implementing the AML/CTF program.
Is a Canadian MSB registration right for your business model, and when is Canada the wrong choice?
The Retail Payment Activities Act (S.C. 2021, c. 23) requires mandatory PSP registration and fund-safeguarding for end-user funds holding.
What does it take to keep a Canadian MSB registration, and what is changing?
PCMLTFR s. 156(1)(f) and (3) require instituting a review plan and carrying out a review to test compliance program effectiveness every two years.
Sources
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- Justice Laws of Canada: P 24.501 · retrieved 2026-09-24
- Justice Laws of Canada: SOR 2002 184 · retrieved 2026-09-24
- Justice Laws of Canada: SOR 2007 121 · retrieved 2026-09-24
- bankofcanada.ca: psp registry · retrieved 2026-09-24
- fintrac-canafe.canada.ca: reg ins eng · retrieved 2026-09-24
- fintrac-canafe.canada.ca: reg eng · retrieved 2026-09-24
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- amlincubator.com: theres no such thing as an msb license in canada its only a · secondary · retrieved 2025
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- ca.vlex.com: kabul farms inc v 679849101 · retrieved 2016-05-05
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