How to register an MSB in Canada

Step 1: Check whether you need to register

In Canada, a money services business (MSB) is a business that provides certain money services. If you have a place of business in Canada and you provide any of these, you must register with FINTRAC, the Financial Transactions and Reports Analysis Centre of Canada, before you start:

• foreign exchange dealing;
• remitting or transmitting funds;
• issuing or redeeming money orders, traveller's cheques or similar negotiable instruments;
• dealing in virtual currency;
• crowdfunding platform services;
• armoured car services;
• cheque cashing;
• acquirer services for private automated banking machines.

If you have no place of business in Canada but you direct and provide these services to people or entities in Canada, you're a foreign MSB, and you must register too. Our foreign MSB guide covers that case.

Registering or being licensed with a province doesn't replace FINTRAC registration. Quebec, for example, has its own licence for money-services businesses, issued by Revenu Québec, which sits on top of FINTRAC registration.

Is there an "MSB licence" in Canada?

People often search for an "MSB licence". At the federal level, what Canada requires is registration with FINTRAC under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). Quebec is the main exception: it licenses money-services businesses separately. Elsewhere, when someone says "MSB licence Canada", they almost always mean FINTRAC registration.

Step 2: Gather what FINTRAC asks for

FINTRAC's registration asks for:

• details of the business, including incorporation, ownership and senior management;
• bank account information;
• your compliance officer;
• how many employees you have, and every location you operate from;
• estimated annual transaction totals for each money service you offer;
• any agents or mandataries that provide services on your behalf;
• for a foreign MSB, a representative for service who lives in Canada;
• documents confirming the business exists and how it's owned and controlled;
• criminal record checks.

Step 3: Order criminal record checks early

FINTRAC needs criminal record checks for the chief executive officer, the president, the directors, and anyone who owns or controls 20% or more of the business, directly or indirectly. A sole proprietor provides one for themselves.

Each check must come from a competent authority in the person's country of residence, be dated no more than six months before you submit it, and be translated if it isn't in English or French. When owners and directors live in different countries, this is often the step that takes longest, so start it first.

Step 4: Submit and answer FINTRAC's questions

Once everything is gathered and checked, you submit your registration to FINTRAC. FINTRAC may come back with questions or ask for more information before it decides. Complete, consistent information is the best way to avoid back-and-forth: the transaction estimates, locations, ownership and documents should all tell the same story.

In our experience, approval takes anywhere from about 1 week to 7 months. Some of our clients have been registered in about a week; the biggest factors are how complete the application is and FINTRAC's workload.

Step 5: Have your compliance program ready

Registration lets you operate; it doesn't make you compliant. From the day you start, you need a compliance program with five parts: a compliance officer, written policies and procedures, a risk assessment, an ongoing training program, and an effectiveness review at least every two years. You also need to identify clients, keep records, generally for at least five years, and report to FINTRAC.

Building the program alongside the registration, rather than after it, means you're ready to operate as soon as you're registered.

Step 6: Stay registered

MSB registration is valid for two years and must be renewed before it expires. Between renewals, tell FINTRAC within 30 days when your registration information changes: a new address, new owners or directors, a new compliance officer, or a change in the services you offer.