Registering a Money Services Business under FINTRAC in Canada in 2025

Money Services Business

If you’re planning to launch a remittance company, foreign exchange platform, or digital payment business in Canada, you’ll need to register with FINTRAC as a Money Services Business (MSB). This is not optional—it’s the legal foundation for operating in the financial services space.

The good news? The registration process is clearly defined and accessible. The bad news? It’s not just a formality. You must meet serious compliance requirements before you go live.

This guide explains how to register an MSB under FINTRAC in Canada in 2025, what you need, how the process works, and how to stay compliant post-registration.

1. What Is FINTRAC?

FINTRAC stands for the Financial Transactions and Reports Analysis Centre of Canada. It’s Canada’s financial intelligence unit responsible for monitoring and enforcing compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) laws.

Under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, all Money Services Businesses must register with FINTRAC to legally operate in Canada—or serve Canadian clients from abroad.

FINTRAC doesn’t issue a “license” in the traditional sense. Instead, it provides registration and oversight, ensuring MSBs are following the rules.

2. Who Must Register as an MSB?

You must register if your business offers any of the following services in Canada:

  • Foreign exchange dealing
  • Remittances and money transfers
  • Issuing or redeeming money orders, traveller’s cheques, bank drafts
  • Dealing in virtual currencies (e.g. wallet service)
  • Crowdfunding platforms (if you handle funds)
  • You can be based inside or outside Canada. Even foreign companies must register if they offer services to Canadian residents.

Common examples of businesses that require MSB registration:

  1. Peer-to-peer payment apps
  2. Prepaid card or wallet operators
  3. White-label financial services
  4. Remittance providers (online or physical)
  5. ATMs and payment processors

3. Step-by-Step Process to Register an MSB with FINTRAC

Let’s walk through the full registration procedure from start to finish.

Step 1: Incorporate Your Business

  • Before applying, you must have a legally registered business.
  • Canadian MSBs must be incorporated federally or provincially
  • Foreign MSBs must have a registered business entity in their home country

You’ll need:

  • A Business Number (BN) from the Canada Revenue Agency (CRA)
  • A clearly defined business structure and ownership record
  • Note: You can’t register as an MSB as an individual—you need a legal entity.

Step 2: Create a Comprehensive Compliance Program

This is the backbone of your registration.

Your compliance program must include:

  • Appointed Compliance Officer
  • A designated person responsible for implementing your AML/CTF program
  • Written Policies and Procedures
  • Tailored to your business operations
  • Covers client onboarding, record-keeping, suspicious transactions, and reporting
  • Risk Assessment
  • Identifies and evaluates your exposure to money laundering or terrorism financing risks
  • Includes client types, products, delivery channels, and jurisdictions
  • Training Program
  • Required for all staff involved in compliance, operations, or customer interaction
  • Ongoing Compliance Review Plan
  • Annual review of your AML/CTF controls
  • Tip: Don’t download a generic template—FINTRAC wants to see a customised, real-world plan.

Step 3: Register Online with FINTRAC

You’ll complete the MSB Registration Form, which includes:

  • Business details (legal name, address, incorporation number)
  • Business activities (select all MSB services offered)
  • Compliance officer information
  • Ownership details (including ultimate beneficial owners)
  • Bank account information (if already set up)
  • Service delivery methods (online, in-person, mobile)
  • There is no registration fee.

Step 4: Await Confirmation and Respond to FINTRAC Queries

FINTRAC reviews your application and may:

  • Approve it immediately
  • Ask for more details (especially regarding your compliance plan)
  • Request edits or clarification
  • Be responsive and clear in all communication. Incomplete or vague responses will delay approval.
  • Typical review time: 2–6 weeks, depending on complexity.

4. Required Documents and Details

During the process, you’ll be asked to provide or prepare:

  • Incorporation documents or business registration certificate
  • CRA-issued Business Number (BN)
  • Names and ID of all beneficial owners (owning 25%+)
  • Compliance program documents (policy, risk assessment, training plan)
  • Details of products/services offered
  • Intended client base and regions served
  • AML screening tools (if in place)
  • Details of any foreign affiliates or partners
  • For MSBs: Prepare detailed documentation of your blockchain services, wallet types, and KYC flow.

5. Foreign MSBs: Serving Canadian Clients from Outside Canada

If you’re not based in Canada but serve Canadians, you’re considered a Foreign MSB and must still register.

You’ll need to:

  • Complete the same FINTRAC registration form
  • Submit a Canadian address for communication purposes
  • Provide extra information on how you onboard Canadian clients
  • Ensure your compliance documents reflect Canadian AML standards
  • Tip: Many exchanges in Europe, Asia, and the U.S. now register as Foreign MSBs to stay compliant in Canada.

6. After You’re Registered: Ongoing Responsibilities

Registration is not the end of the process—MSBs have ongoing obligations under Canadian law.

You must:

  • File a biennial renewal of your registration
  • Submit reports to FINTRAC, including:
  • Suspicious Transaction Reports (STRs)
  • Large Cash Transaction Reports (LCTRs) over CAD 10,000
  • Large Virtual Currency Transaction Reports (LVCTRs)
  • Update any material changes (ownership, business model, address, compliance officer)
  • Maintain records for 5 years, including client data and transaction history
  • Prepare for FINTRAC audits or inspections

Failure to comply can result in:

  • Administrative monetary penalties (AMPs)
  • Revocation of your MSB status
  • Criminal charges in extreme cases

7. Special Requirements for Virtual Currency MSBs

If your MSB deals with virtual currencies, there are additional compliance requirements.

You must:

  • Collect and verify identification for clients (even for wallet-to-wallet transfers)
  • Monitor transaction patterns and flag suspicious blockchain activity
  • Keep logs of wallet addresses and blockchain transactions
  • Report LVCTRs (CAD 10,000+ in virtual currencies within 24 hours)
  • Be ready to explain your source of liquidity and counterparties
  • FINTRAC treats  transactions the same as cash: high risk, high visibility.

8. Can You Open a Business Bank Account as an MSB?

Yes—but it’s not always easy.

Many major banks in Canada are cautious about onboarding MSBs, particularly if you’re involve or high-risk jurisdictions.

To improve your chances:

  • Have a complete and clean FINTRAC registration
  • Present your compliance program and internal controls
  • Be transparent about your business model and customers
  • Choose banks with fintech or startup-friendly departments
  • Alternatively, consider working with:
  • Credit unions
  • Fintech banks
  • International institutions if local banks decline

Pro tip: Don’t wait until the last minute to open an account. It can take weeks, even with full documentation.

9. Common Mistakes to Avoid

  • The most common problems when registering with FINTRAC include:
  • Submitting generic conformity documents
  • Failing to designate a real Compliance Officer
  • Misclassifying your business activity
  • Not disclosing beneficial owners
  • Assuming registration is a one-time task—it’s not

Solution: Take the process seriously. If needed, work with a Canadian legal or compliance advisor with MSB experience.

MSB vs. Other Financial Licenses: Know the Limits

Registering as an MSB lets you perform certain financial functions—but it is not a banking license.

You can:

  • Exchange money
  • Handle remittances
  • Deal in virtual currencies
  • Operate payment or wallet services
  • You cannot:
  • Take deposits
  • Offer loans or credit
  • Act as a bank or investment advisor
  • Issue securities or manage portfolios

If your business involves these activities, consult a lawyer—you may need provincial securities or lending licenses.

Is FINTRAC Registration Public?

Yes. Once your MSB is registered, your business will appear on FINTRAC’s public registry of Money Services Businesses.

What’s visible:

  • Legal and operating name
  • Business address
  • Type of MSB favors offered
  • Registration number
  • Registration status (active, revoked, expired)
  • This transparency allows banks, clients, partners, and regulators to verify your status. It also adds credibility and trust to your operation.

Tip: Keep your listing accurate and up to date. If your business moves, expands services, or changes ownership, you must report it to FINTRAC within 30 days.

Final Thoughts

Registering a Money Services Business under FINTRAC in Canada is a clear, rules-based process. It’s not cheap or fast—but it’s fair, transparent, and globally respected.

If you want to operate in Canadian fintech, payments, FINTRAC registration is your first legal milestone. It shows you’re serious about compliance, risk management, and consumer protection.