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Canada money services business registration

At a glance

Regulator
FINTRAC
Timeline
3 months
Term
2 years

Reviewed by Harry Khan, Founder · 26 October 2026

Canadian money services business (MSB) registration is a federal filing with FINTRAC, Canada’s financial intelligence unit, for remittance, foreign exchange and virtual currency firms, foreign ones included.

Who it is for

An MSB with a place of business in Canada that offers foreign exchange dealing; remitting or transmitting funds, including invoice payment and payment services for goods or services; issuing or redeeming money orders, traveller’s cheques or similar instruments; dealing in virtual currency by exchange or transfer; crowdfunding platform services; or armoured car, cheque cashing and private ABM acquiring services registers under section 11.1 of the Act. Advertising such services, holding a related licence or reporting the activity for tax purposes also brings a business in scope.

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A foreign MSB with no place of business in Canada registers where it directs services at persons in Canada, for example through Canadian marketing, a .ca domain or a Canadian directory listing, and serves clients in Canada.

Agents and mandataries do not register separately, and provincial licensing, for example in Quebec, is additional to FINTRAC registration. A business performing payment functions also registers with the Bank of Canada, described below.

FINTRAC treats a business as having a place of business in Canada if it is incorporated in Canada, has a physical location in Canada, or has employees, agents or branches in Canada. Invoice payment services and payment services for goods or services count as remitting or transmitting funds.

Outside that service are a business that only accepts payment for goods or services it supplied to its own customer, one that only supplies hardware such as a payment terminal, and one that only receives payments on behalf of a payee to settle a debt without passing the payment instructions on. A business is not an MSB where it acts strictly as an agent or mandatary of an MSB, or carries out the activity in the course of other services for which it is already a reporting entity, such as a securities dealer exchanging currency to buy securities for a client.

What FINTRAC requires

Place of business or representative
An MSB has a place of business in Canada; a foreign MSB appoints a representative for service resident in Canada and reports any change of representative within 30 days.
Criminal record checks
For the chief executive, president, directors and owners of 20% or more, issued within six months by the country of residence, with certified translations.
Eligibility
The applicant and its chief executive.
Compliance programme
Five elements: an appointed compliance officer.
Registration form
Bank account information, the compliance officer.
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  • Eligibility. The applicant and its chief executive, president, directors and 20% owners must be free of convictions for money laundering, terrorist financing, specified offences under the Act, drug offences other than simple possession, Criminal Code offences involving terrorist groups, proceeds of crime or fraud, weapons, human trafficking and listed repeat offences; listed terrorist entities are ineligible.
  • Compliance programme. Written policies and procedures approved by a senior officer; a documented risk assessment covering money laundering, terrorist financing and sanctions evasion; a written ongoing training programme and plan; and an effectiveness review at least every two years, reported to a senior officer within 30 days.
  • Registration form. Bank account information, the compliance officer, employees, incorporation details, the names and dates of birth of owners and senior management, projected annual volumes per service, all locations and all agents, or the representative for service for a foreign MSB.
  • Ongoing obligations. Changes to the contact person or representative for service reported within 30 days; clarification requests answered within 30 days; cessation reported within 30 days; renewal before the two-year expiry.
  • Pre-registration. Registration starts with FINTRAC’s pre-registration form. A FINTRAC compliance officer then sends the registration form, and the completed form goes back through a Secure Document Transfer System link that expires within 15 days. Registration with a province or territory does not replace it.
  • Existence and governance documents. A certificate of incorporation or equivalent record naming the directors, and a document setting out ownership, control and structure. Criminal record checks in another language are translated into English or French by a certified translator, with the statement of certification, and kept for at least five years.
  • Outcome. FINTRAC sends a registration approval notice with the registration number, a clarification request, or written reasons for denial; approved registrations appear on FINTRAC’s public Money Services Business Registry.
  • Registration changes. Changes to contacts, agents, locations and activities are reported within 30 days.
  • Foreign MSB responsibility. The foreign MSB, not its representative for service, remains responsible for its obligations. Canadian financial entities must confirm that any foreign MSB for which they open an account, or with which they hold a correspondent banking relationship, is registered.
  • Agents and mandataries. Since 1 October 2025 an MSB verifies each agent’s eligibility before engaging it, and again within 30 days after the second anniversary of the last verification, obtaining criminal record checks for an entity agent’s chief executive, president, directors and 20% owners. Agents engaged before that date are brought into line by 1 October 2027. Failing to do so is an offence carrying, on indictment, a fine of up to C$500,000, up to five years’ imprisonment, or both.

Timeline

Statutory decision period
No statutory period
Regulator’s published figure
Most complete applications processed within 3 months; more complex applications take longer
Application preparation
3 to 4 weeks
Our timeline
3 months after submission
Read more

Regulator figures are quoted as published and converted to months. Our timeline assumes a complete, well-prepared application.

Capital

RequirementAmount
Capital requirementNone stated
Safeguarding (FINTRAC)Not a requirement of the Act
Safeguarding (Bank of Canada, payment service providers)End-user funds segregated, held in trust or covered by insurance or a guarantee from an unaffiliated qualifying institution at least equal to the safeguarded amount
Read more

Where the trust method is used the Bank of Canada expects a written legal opinion confirming a valid express trust; CDIC deposit insurance alone does not meet the requirement.

How we help

We prepare Canada MSB registration applications, file them with FINTRAC and manage each one to approval, from our offices in London and New York.

Authorisation is the first stage. We can also arrange what the regulator expects to be in place alongside it: the local directors and compliance officer, bank and safeguarding accounts, payment processing and the first year of compliance.

See also: Hong Kong money service operator licence

Get in touch

Get in touch

Tell us where you are and where you want to be.

[email protected]
+44 7563 115980 (phone and WhatsApp)

Further detail

Summary

  • A business with a place of business in Canada that deals in foreign exchange, remits or transmits funds, issues or redeems money orders, deals in virtual currency or provides crowdfunding platform services registers with FINTRAC as a money services business.
  • A foreign MSB with no place of business in Canada registers where it directs services at persons in Canada and serves clients there, and appoints a representative for service resident in Canada.
  • There is no capital requirement and FINTRAC charges no registration fee.
  • FINTRAC states that most complete applications are processed within three months; the registration is valid for two years.
  • The compliance programme has five elements: a compliance officer, written policies approved by a senior officer, a documented risk assessment, a training programme and an effectiveness review at least every two years.
  • Payment service providers also register with the Bank of Canada under the Retail Payment Activities Act for a flat C$2,500 fee, with safeguarding of end-user funds in force since 8 September 2025.

Background

There is no capital and no FINTRAC fee; most complete applications are processed within three months and registration lasts two years. Payment service providers also register with the Bank of Canada for C$2,500.

Remittance, foreign exchange and virtual currency businesses serving Canada, foreign firms included, register with FINTRAC, and payment service providers also register with the Bank of Canada.

Before anything is drafted we advise on whether this is the right authorisation for the business, or whether another route would serve it better.

How to apply, step by step

The FINTRAC and Bank of Canada sequence. FINTRAC’s three months and the 15-day and 30-day limits are FINTRAC’s own; the other times are our planning figures.

  1. Confirm the services and the registration type1 week. Map each service against the Act: foreign exchange, remittance or transmission, money orders, virtual currency, crowdfunding, armoured car, cheque cashing or private automated banking machines. A firm with no place of business in Canada registers as a foreign MSB.
  2. Build the compliance programme3 to 4 weeks. Five elements: a compliance officer, written policies approved by a senior officer, a documented risk assessment, a training programme and an effectiveness review at least every two years.
  3. Obtain criminal record checks2 to 4 weeks. For the chief executive, president, directors and owners of 20% or more, issued within six months by the country of residence, with certified translations.
  4. Open the Canadian bank accountIn parallel. Bank account information is part of the registration form, so the account comes first; a foreign MSB also appoints a representative for service resident in Canada.
  5. Submit the FINTRAC registrationUpload within 15 days of receiving the link. Complete the form with owners, senior management, projected volumes per service, locations and agents, and upload it through FINTRAC’s secure link within 15 days or the application closes.
  6. Answer clarification requests to a decisionAbout 3 months. FINTRAC processes most complete applications within three months; each clarification request must be answered within 30 days or the application is denied.
  7. Register with the Bank of Canada if you perform payment functionsFrom application to notice. A payment service provider applies under the Retail Payment Activities Act with the C$2,500 fee; the Department of Finance has 60 days for a national security review where the Minister considers one necessary.
  8. Maintain and renewEvery two years. Report changes to the contact person or representative within 30 days, run the effectiveness review at least every two years and renew before the two-year registration expires.

Registration types

RegistrationWhoLocal presence
Money services business (FINTRAC)A business with a place of business in Canada providing an MSB servicePlace of business in Canada
Foreign money services business (FINTRAC)No place of business in Canada; directs services at and serves persons in CanadaRepresentative for service resident in Canada
Payment service provider (Bank of Canada)Performs any of five payment functions in fiat currency as a service in its own rightPlace of business in Canada, or serving and directing services at persons in Canada

Reporting and record keeping

A registered MSB, foreign MSBs included, files these reports with FINTRAC and keeps these records.

Suspicious transaction report
Any amount, as soon as practicable once there are reasonable grounds to suspect; suspected sanctions evasion is reported too
Large cash transaction report
C$10,000 or more in cash, including smaller amounts combined under the 24-hour rule
Large virtual currency transaction report
C$10,000 or more in virtual currency, under the 24-hour rule
Electronic funds transfer report
Each international electronic funds transfer of C$10,000 or more that the MSB initiates or finally receives, under the 24-hour rule
Travel rule
Originator and beneficiary information included with each electronic funds or virtual currency transfer for which a record is kept: C$1,000 or more
Listed person or entity property report
Property of a listed person or entity in the MSB’s possession or control
Records
Kept for at least five years

First-year cost

Regulator application fee
None at FINTRAC; C$2,500 at the Bank of Canada for a payment service provider, flat and non-refundableFINTRAC; Bank of Canada
Initial capital
No feeNo capital requirement under the Act
Annual regulator or supervisory fee
None at FINTRAC; the Bank of Canada’s annual assessment formula is published but not charged until the regulations are finalisedFINTRAC; Bank of Canada
Audit
An effectiveness review of the compliance programme at least every two years, reported to a senior officer within 30 daysFINTRAC compliance programme requirements
Required roles
An appointed compliance officer and a senior officer who approves the policies; a representative for service resident in Canada for a foreign MSBFINTRAC
Insurance or safeguarding
For a payment service provider, end-user funds segregated, held in trust, or covered by insurance or a guarantee at least equal to the safeguarded amountBank of Canada safeguarding framework, in force since 8 September 2025

Regulator data

FINTRAC publishes its processing standard rather than approval counts: most complete applications are processed within three months, longer for complex ones. It closes incomplete applications, denies those where a clarification request goes unanswered for 30 days, and denies or revokes registration where the applicant or a chief executive, president, director or 20% owner is ineligible. The Bank of Canada publishes its registry of payment service providers, the list of applicants and the list of refused or revoked registrations.

Penalties and enforcement

The Strengthening Canada’s Immigration System and Borders Act (Bill C-12) received Royal Assent on 26 March 2026. For violations after that date FINTRAC can apply maximum administrative monetary penalties up to 40 times the previous limits, take ability to pay into account, require mandatory compliance agreements for prescribed violations and issue compliance orders. FINTRAC publishes every penalty it imposes.

BusinessPenaltyDate imposedStatus
Xeltox Enterprises Ltd. (Cryptomus), MSB, British ColumbiaC$176,960,190 for 2,593 contraventions across 6 types of violation16 October 2025Appealed to the Federal Court
Peken Global Limited (KuCoin), foreign MSB, SeychellesC$19,552,000 for 3 violations28 July 2025Appealed to the Federal Court
MP Technology Services Ltd., MoonPay subsidiary, foreign MSB, SeychellesC$536,853.35 for 4 violations20 November 2025Appealed to the Federal Court
13010431 Canada Inc. (Necosmart), MSB, EdmontonC$693,742.50 for 5 violations27 March 2026Published 14 May 2026

Bank of Canada registration under the Retail Payment Activities Act

A payment service provider performing any of five payment functions, providing or maintaining an account, holding funds, initiating an electronic funds transfer, authorising or transmitting transfer instructions, or clearing and settlement, as a service that is not incidental to another business, in fiat currency, with a place of business in Canada or serving and directing services at persons in Canada, registers with the Bank of Canada under the Retail Payment Activities Act.

Revenue level is irrelevant. Banks and authorised foreign banks, credit unions and other provincially regulated deposit-takers, insurers, trust and loan companies, the Bank of Canada, Payments Canada and SWIFT are excluded, as are agents and mandataries of a registered provider, ATM withdrawals, designated financial market infrastructure functions and intra-group transactions.

The application fee is a flat C$2,500, the same for all applicants and non-refundable; the annual assessment fee formula is published and is not charged until the regulations are finalised. Providers that began after 8 September 2025 must receive a registration decision before performing any retail payment activity.

The risk management and safeguarding frameworks have been in force since 8 September 2025 and the annual report is due by 31 March. The Bank publishes the registry of providers, a list of applicants and refused or revoked registrations.

On 12 June 2026 the Bank announced that it would begin publishing notices of violation by payment service providers. Under the Stablecoin Act the Bank will also register non-financial issuers of stablecoins to Canadians, supervise their compliance, monitor issuance and redemption risks and take enforcement action; the Department of Finance has published proposed regulations in Part I of the Canada Gazette.

The Quebec licence

Revenu Québec issues the licences that money services businesses need under Quebec’s Money-Services Businesses Act, and inspects and investigates them. A business may operate an MSB in Quebec only once Revenu Québec has issued its licence.

Revenu Québec asks the Sûreté du Québec and the local municipal police force for security clearance reports on the business and each associated person, covering previous convictions and good moral character; the Sûreté du Québec reports take about 30 days and each one is invoiced. Fees vary with the money services the application covers, and automated teller machines need a licence and a decal for each machine. A national launch plans the Quebec licence as a separate workstream alongside FINTRAC registration.

Geographic scope

FINTRAC registration is federal and covers the whole of Canada; provincial MSB licences, for example in Quebec, are additional. Groups serving North America pair it with the FinCEN registration and the state money transmitter licences in the United States; we obtain each.

Your bank accounts

Bank account information is part of the registration form, so the account comes first. Canadian banks review the compliance programme and, for payment service providers, the Bank of Canada safeguarding arrangement before opening accounts. We open them alongside the registration. See banking and payment processing.

What the work covers

3 monthsTimeline

From submission to the regulator's decision, for a complete application.

From authorisationBanking

Safeguarding, operating and settlement accounts opened alongside the application, so the business can trade once authorised.

Your teamPeople

We assemble your team: a compliance officer and directors.

How we work on the application

  1. Scoping. We confirm the MSB services in scope, whether you register as an MSB or a foreign MSB, and whether Bank of Canada registration under the Retail Payment Activities Act also applies.
  2. Application pack. The registration form with owners, senior management, locations, agents and projected volumes, the criminal record checks and the five-element compliance programme, uploaded through FINTRAC’s secure link within the 15 days allowed.
  3. Banking. Your Canadian bank account, opened first because its details go in the registration form, and the Bank of Canada safeguarding arrangement where that registration applies.
  4. Filing and renewal. We answer FINTRAC clarification requests within 30 days, report changes to the contact person or representative for service within 30 days, and renew the registration before its two-year expiry.

Your team, banking and technology

You will need a compliance officer, a chief executive and directors with clean criminal record checks, and a representative in Canada if the business is abroad.

Key peopleWe assemble your team: a compliance officer and directors.
BankingSafeguarding, operating and settlement accounts, card acquiring and payment processing, opened alongside the application.
TechnologyAccount, payment, wallet and card programme technology in place for launch.

Questions

How long does FINTRAC registration take?

FINTRAC states that most complete applications are processed within three months of receiving a complete package; complex applications take longer. We plan for three months after submission.

Is there a fee for FINTRAC registration?

No. FINTRAC charges no registration or annual fee. The Bank of Canada charges a flat C$2,500 application fee for payment service provider registration.

Does a foreign company need to register?

Yes, as a foreign MSB, where it directs services at persons in Canada and serves clients there without a place of business in Canada; it appoints a representative for service resident in Canada and reports any change within 30 days.

Do we also need Bank of Canada registration?

Yes, where the business performs a payment function such as holding funds or initiating or transmitting electronic funds transfers as a service in its own right; the application fee is C$2,500, and a provider that began after 8 September 2025 must be registered before performing any retail payment activity.

How long is the registration valid?

Two years, renewed before expiry; changes to the contact person or representative for service are reported within 30 days.

Is there a capital requirement for a Canadian MSB?

No. The Act sets no capital requirement and FINTRAC charges no fee; the main cost is the compliance programme, with its effectiveness review at least every two years.

Is FINTRAC registration a licence?

No. It is a registration under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. FINTRAC checks the application, eligibility and criminal records, then supervises compliance; it sets no capital and charges no fee.

Can we operate while FINTRAC registration is pending?

No. Money services businesses and foreign MSBs register with FINTRAC before they begin to operate.

Does FINTRAC registration cover Quebec?

It meets the federal requirement across Canada, but a business operating money services in Quebec also needs a licence from Revenu Québec under the Money-Services Businesses Act.

How do we check whether an MSB is registered?

On FINTRAC’s public Money Services Business Registry, where approved registrations appear after FINTRAC sends the approval notice and registration number.

Sources

  1. FINTRAC: money services businesses
  2. FINTRAC: register your MSB or foreign MSB
  3. FINTRAC: responding to FINTRAC, renewals, changes and denial
  4. Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 11.1
  5. Bank of Canada: criteria for registering payment service providers
  6. Bank of Canada: frequently asked questions about retail payments supervision
  7. FINTRAC: clarification requests, updates, renewal and cessation
  8. FINTRAC: administrative monetary penalties after the 2026 amendments
  9. FINTRAC: public notice of administrative monetary penalties
  10. FINTRAC: travel rule for electronic funds and virtual currency transfers
  11. FINTRAC: record keeping requirements for MSBs
  12. FINTRAC: reporting electronic funds transfers
  13. Revenu Québec: role and responsibilities for money-services businesses
  14. Revenu Québec: licence application details
  15. Bank of Canada: stablecoins

This guide is general information, not legal advice. Requirements and fees change, and the regulator’s own publications take precedence.

Cited in the sections above

Who needs the licence. Sources: FINTRAC: money services businesses.

Reporting and record keeping. Sources: FINTRAC: money services businesses; FINTRAC: reporting electronic funds transfers; FINTRAC: travel rule; FINTRAC: record keeping for MSBs.

What it costs in the first year. Sources: FINTRAC: register your MSB or foreign MSB; FINTRAC: money services businesses; Bank of Canada: criteria for registering payment service providers; Bank of Canada: retail payments supervision FAQ.

Regulator data. Sources: FINTRAC: register your MSB or foreign MSB; FINTRAC: responding to FINTRAC, renewals, changes and denial; Bank of Canada FAQ.

Penalties and enforcement. Sources: FINTRAC: administrative monetary penalties, changes following legislative amendments; FINTRAC: public notice of administrative monetary penalties.

Bank of Canada registration under the Retail Payment Activities Act. Sources: Bank of Canada: stablecoins.

The Quebec licence. Sources: Revenu Québec: role and responsibilities for MSBs; Revenu Québec: licence application details.

  • Timing, Statutory decision period: Proceeds of Crime (Money Laundering) and Terrorist Financing Act, section 11.1
  • Timing, Regulator’s published figure: FINTRAC, register your MSB or foreign MSB
  • Timing, Application preparation: From instruction to submission, including banking in parallel
  • Timing, Our timeline: Our own figure, from the regulator’s published data and our applications

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