Canada · Registration
FINTRAC MSB Registration in Canada
Money services business registration under the PCMLTFA — a compliance obligation you register into, not a licence you are approved or refused. No capital, no fee, no approval queue. The work is the programme underneath it.
At a glance
Do you need to register?
Three tests. All three must be true.
Most founders arrive here unsure whether they are caught at all. The test is narrower than it looks, and there is no size threshold hiding in it.
Where you operate
You have a place of business in Canada — or you don't, but you direct services at customers in Canada. The second case is the Foreign MSB (FMSB) route, and it needs no Canadian entity at all.
What you do
You perform at least one of the nine activities below. One is enough — there is no minimum volume, no revenue floor and no grace period for small operators.
When you start
You must be registered before you begin to operate. This is the test founders most often get wrong, because it cannot be corrected retrospectively.
Not sure if you are caught?That is the most common reason to talk to us first. Scoping the perimeter correctly — including whether you need the Bank of Canada’s separate RPAA registration as well — costs far less than registering for the wrong thing.
Qualifying activities
Nine activities. One is enough.
FINTRAC does not grant a scoped licence the way the FCA does — registration attaches to whichever of these you actually perform. Six are named directly in the PCMLTFA at paragraph 5(h); two are prescribed services added by the regulations; and PSP is FINTRAC’s own Registry label rather than a separate category in law. Titles match the terminology on the public MSB Registry, so they are recognisable when you look your own registration up.
Foreign Exchange
Foreign exchange dealing.
Named directly in the Act
Money Transferring
Remitting funds or transmitting funds by any means or through any person, entity or electronic funds transfer network.
Named directly in the Act
Armoured Cars
Transporting currency or money orders, traveller's cheques or other similar negotiable instruments.
Named directly in the Act
Issuing and Redeeming Money Orders
Issuing or redeeming money orders, traveller's cheques or other similar negotiable instruments.
Named directly in the Act
Virtual Currency
Dealing in virtual currencies.
Named directly in the Act
Private ABM Acquirer Services
In relation to a private automated banking machine, acquirer services.
Named directly in the Act
Crowdfunding
Providing and maintaining a crowdfunding platform for use by other persons or entities to raise funds or virtual currency for themselves or for persons or entities specified by them.
PCMLTFA s.5(h)(v); defined at PCMLTFR s.1(2)
Cheque Cashing
Cashing cheques for clients in exchange for funds.
PCMLTFA s.5(h)(v); defined at PCMLTFR s.1(2)
Payment Service Provider (PSP)
Payment processors — invoice payment services, or payment services for goods and services on behalf of merchants. Not a separate category in law: FINTRAC treats these as money transferring or virtual currency dealing, and uses PSP as the label on its public Registry.
FINTRAC clarification notice, 21 July 2022
Two different things in Canada are called “PSP”
This one is FINTRAC’s AML registration under the PCMLTFA. The Bank of Canada’s Retail Payment Activities Act registration is a separate regime — many payment businesses need both, and neither covers the other.
Requirements in detail
What you actually need.
Incorporation
A standard MSB registration is for a Canadian entity — a business already incorporated or established in Canada. If you aren't one, FINTRAC has a distinct category for exactly that: a Foreign MSB (FMSB) registers directly with no Canadian entity, substituting a Canada-resident Representative — an individual authorised to receive notices and legal documents from FINTRAC on your behalf. That is the whole incorporation-side distinction. Everything else FINTRAC asks for concerns your compliance programme, not your corporate structure.
Capital
None. FINTRAC sets no minimum capital, charges no application fee, and makes no merits-based approval decision. It is worth being precise about what that does and doesn't mean: the absence of a capital test is not an absence of scrutiny — it moves the entire burden onto your compliance programme, which is assessed on examination rather than at the door.
Directors
No FINTRAC-specific minimum — this follows whatever your incorporating jurisdiction's corporate law requires. For a federally incorporated company under the Canada Business Corporations Act (CBCA), the floor is one director, rising to a 25% Canadian-residency requirement once you have four or more.
Governance & people
A Compliance Officer is mandatory — someone with genuine authority to run the AML programme. FINTRAC sets no formal credential requirement, though in practice most registrants appoint someone with several years of relevant experience. What the Act does require directly, at PCMLTFA s.11.12: criminal record checks no older than six months for your CEO, President, every director, and anyone owning 20% or more of the business — a recent requirement, only fully in force since 2025. Note this 20% figure is about screening your own people, and is separate from the 25% threshold at which you must identify the beneficial owners of your corporate *customers*.
Ongoing obligations
Registration starts the obligation rather than completing it. You will file Large Cash Transaction Reports (cash of CAD $10,000 or more) within 15 calendar days; Electronic Funds Transfer Reports at the same threshold; Large Virtual Currency Transaction Reports if you deal in crypto; and Suspicious Transaction Reports, which have no minimum threshold at all and are filed as soon as practicable once you have reasonable grounds to suspect. A documented two-year effectiveness review of the programme is mandatory, most information changes must reach FINTRAC within 30 days, and the registration itself renews every two years.
Provincial overlap — Quebec
Not always applicable, but expensive to discover late: if you serve anyone in Quebec you need a separate licence from Revenu Québec (forms SM-3-V and SM-3.A-V), administered independently of FINTRAC. The Quebec licence runs April 1 to March 31 and is renewed annually rather than every two years. Revenu Québec targets 50 calendar days once a complete file is filed — but a paid Sûreté du Québec security clearance is required for every associated person, and that is what actually sets the pace.
Not sure which activities you trigger?
A scoping call maps your perimeter, confirms MSB versus Foreign MSB, and tells you whether Quebec or the RPAA are in scope — before any documentation work starts.
Time & cost
What actually drives both.
We would rather tell you what governs the timeline than quote a number we cannot stand behind. FINTRAC publishes no processing service standard for MSB registration.
There is no published service standard
FINTRAC does not publish a processing service standard for MSB registration, so any firm quoting you a guaranteed date is estimating. What is certain is the part that matters: there is no discretionary approval queue. Once your file is complete and correct, you are registered.
Criminal record checks set the floor
Checks for your CEO, President, every director and each 20%+ owner are external processes you cannot compress, and they must be no more than six months old at submission. Overseas individuals need an equivalent check, which typically takes longer.
The compliance programme is the real work
FINTRAC expects the programme to exist and be operating, not to be promised. Building the risk assessment, policies, procedures and training — and appointing a Compliance Officer with real authority — is the bulk of the elapsed time on almost every engagement.
Banking usually takes longer than registration
Canadian banking access is the practical bottleneck for most MSBs, not FINTRAC. Banks run their own due diligence on your AML programme, and a weak or generic programme is the most common reason onboarding stalls. This is a strong argument for building the programme properly rather than to the minimum.
Quebec runs in parallel, not after
If Quebec is in scope, the Revenu Québec application and its per-person police clearances should start alongside the federal file, not once it completes. Sequencing them is the single most common avoidable delay.
FINTRAC
No feeFINTRAC charges no registration fee and sets no minimum capital. Registration itself costs nothing.
Quebec (if in scope)
Fees applyRevenu Québec licence fees and tariffs are payable and non-refundable, plus a Sûreté du Québec security clearance fee for each associated person, payable when you file. Current figures come from Revenu Québec's published tariff list, which is indexed periodically — we confirm live figures before you commit.
Your real cost
The programmeThe compliance programme and the people to run it. A Compliance Officer is mandatory from day one, and the programme must be genuinely operating — this, not the registration, is where the budget goes.
Our fee
Scoped and fixed before any documentation work begins, once the first call has established which activities you trigger, whether you register as an MSB or a Foreign MSB, and whether Quebec is in scope. No hourly drift.
Process
From scoping to registered and banked.
Scoping & programme design
Confirm which of the nine activities you actually trigger, whether you register as an MSB or a Foreign MSB, and whether Quebec is in scope. Then design the compliance programme FINTRAC expects: risk assessment, written policies and procedures, a designated Compliance Officer, ongoing training, and a documented effectiveness-review plan.
Documentation & screening
Build the programme documentation and start the criminal record checks early — they are external, they expire after six months, and they are the most common cause of a stalled file.
Registration & Quebec in parallel
Submit a Pre-registration request; FINTRAC issues a bespoke registration form and exchanges documents via secure Canada Post Connect message. There is no self-service portal. A Foreign MSB names its Canada-resident Representative at this stage, and any Quebec application runs alongside rather than after.
Live, banked & maintained
You are registered and obligations are live from day one. We support bank onboarding with the programme evidence banks actually ask for, then keep it running — monitoring, reporting, the two-year effectiveness review and renewal.
What we prepare
The compliance programme.
26 documents, or 30 if Quebec is in scope. Illustrative — deliberately leaner than a UK/EU authorisation pack, because this is a compliance-programme registration rather than a capital-and-governance licensing process.
AML/CTF Compliance Programme
The same core programme structure behind our UK EMI work, adapted to FINTRAC's terminology, plus the Canada-specific reporting obligations that have no UK equivalent.
Policies & risk
Client due diligence & monitoring
Canada-specific reporting
Governance & assurance
Mapped to FINTRAC's Compliance Programme Requirements guideline. Plus supporting forms and registers.
Registration & Governance
What FINTRAC needs in order to register you, and what you must retain afterwards.
Plus supporting forms.
Quebec Supplementary Licensing
Only if you serve Quebec customers — a genuinely separate workstream, administered by Revenu Québec rather than FINTRAC.
Conditional — omitted entirely if Quebec is out of scope.
We build this pack, not a template of it.
Every document is written against your actual activities, customers and jurisdictions — which is also what makes it survive a bank’s due diligence, not just FINTRAC’s.
Who does the work
Senior people, start to finish.
Every registration is scoped, built and submitted by senior team members who understand fintech and this specific regime — never delegated to a junior bench.
FAQ
Questions worth asking up front.
No. FINTRAC's rule is that money services businesses — and foreign money services businesses directing services at clients in Canada — must register before they begin to operate. This is not a technicality that can be tidied up later: failing to register has itself been one of the violations in FINTRAC's largest enforcement actions, including a penalty against a foreign crypto exchange that was cited specifically for operating without registering. If you are already trading unregistered, that is a remediation conversation, and it should happen quickly.
Honestly: nobody can promise you a date, because FINTRAC publishes no processing service standard for MSB registration. What we can tell you is what governs the pace. There is no discretionary approval queue — once the file is complete and correct, you are registered. The elapsed time is set by criminal record checks (external, and invalid after six months), by how quickly the compliance programme can be built to a standard that survives examination, and — if applicable — by Quebec's parallel process with its per-person police clearances. In practice, Canadian bank onboarding often takes longer than the FINTRAC registration itself.
This is the question that decides whether an MSB actually operates, and it deserves a straight answer: Canadian banking access for MSBs is genuinely difficult, and registration alone does not secure it. Banks run their own due diligence and will assess your AML programme directly. A generic, templated programme is the most common reason onboarding stalls — which is precisely why building it properly is worth more than building it cheaply.
No, and the shared acronym causes real confusion. FINTRAC uses "PSP" on its MSB Registry as a label for payment processors that fall under money transferring or virtual currency dealing — it is an AML/CFT registration under the PCMLTFA. The Bank of Canada separately administers the Retail Payment Activities Act, which registers payment service providers for operational risk and the safeguarding of end-user funds. Different regulator, different statute, different registration. Many payment businesses need both, and neither covers the other.
Not on open-ended grounds — that is the core difference from UK or EU authorisation. FINTRAC makes no merits-based judgment. It can deny or revoke only against defined statutory ineligibility criteria: specific money-laundering, terrorist-financing or drug-trafficking convictions, or listed-terrorist status, affecting the business or its CEO, president, directors or 20%+ owners. If you meet the definitional criteria and register correctly, you are registered. The real risk is not refusal — it is registering incorrectly, or under-scoping the compliance programme that will later be examined.
It depends which category you register under. A standard MSB registration is for a Canadian entity. If you do not have one, FINTRAC's Foreign MSB (FMSB) category lets you register directly with no Canadian entity at all — you appoint a Canada-resident Representative instead, to receive notices and legal documents on your behalf. That is a person, not necessarily a company.
Checks no older than six months for your CEO, President, every director, and anyone owning 20% or more of the business — codified at PCMLTFA s.11.12 and only fully in force since 2025. Do not confuse this with FINTRAC's separate 25% beneficial-ownership concept: the 20% figure is about screening your own people; the 25% figure is a due-diligence obligation you perform on your corporate customers.
No. Quebec requires its own separate licence (forms SM-3-V and SM-3.A-V) from Revenu Québec, which took over MSB licensing from the AMF in 2021. It runs April 1 to March 31 and renews annually rather than every two years. Revenu Québec targets 50 calendar days once your file is complete, but assembling that file — including a paid Sûreté du Québec security clearance for every associated person — is what stretches the real timeline. Start it alongside the federal application, not after it.
Yes. You will also file Large Virtual Currency Transaction Reports (LVCTRs) for any transaction of CAD $10,000 or more, on top of the standard reporting suite. FINTRAC treats this seriously: unfiled LVCTRs featured directly in the largest AML enforcement actions it has taken against money services businesses.
The range is the lesson. In 2025 a Markham, Ontario money services business was penalised $24,750 for failing to notify a change to its registration information, while a Vancouver crypto exchange was penalised $176.9 million for more than 2,500 violations, including over 1,000 unfiled suspicious transaction reports. FINTRAC penalises routine administrative lapses and systemic AML failures alike — the small end of that range is the one most firms underestimate.
No, and this surprises people. There is no live application portal. Registration begins with a Pre-registration form request; FINTRAC then issues a bespoke registration form and exchanges documents with you via secure Canada Post Connect message. The public Money Services Business Registry is a separate, read-only tool for verifying an existing registration — it is not where you apply.
An obligation in force since 1 October 2025. If you assess a CBCA-incorporated corporate client as high risk for money laundering or terrorist financing, you must cross-check their beneficial ownership against Corporations Canada's Individuals with Significant Control (ISC) register — and where there is a material mismatch, file a discrepancy report within 30 days and retain the acknowledgement. It concerns your clients' ownership, not your own.
Other regimes
Not the right fit? See the others.
Register once,
register correctly.
Book a scoping call and we will map exactly which activities you trigger, what the programme needs to contain, and how to get banked once you are registered.