Maksym Stepanenko
Managing Partner, Crystal Tax
International client projects since 2012: company structures, tax, immigration, DUNS and NCAGE. 50+ jurisdictions.
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FINTRAC MSB registration turnkey, often called an MSB licence in Canada: we prepare the corporation, the FINTRAC application and the compliance program, and support you until you are on the registry and after.
Since 2012 · 50+ jurisdictions · MSB and foreign MSB · AML program and renewal in one team
In brief
- FINTRAC MSB registration, often called an MSB licence in Canada, is required for a business that exchanges currency, transfers funds, deals in virtual currency, runs a crowdfunding platform or provides other money services. FINTRAC issues no licences or certificates: the business is entered in the public MSB Registry.
- MSB registration in Canada is mandatory before you start operating if the business has a place of business in Canada. A foreign company with no office in Canada that serves Canadian clients registers as a foreign MSB (FMSB) and names a representative in Canada.
- Turnkey, we incorporate a corporation or prepare an existing one, assemble the FINTRAC registration application and criminal record checks, and write the compliance program: AML/KYC policies, risk assessment, training, appointment of a compliance officer. We then handle renewal and changes.
- Registration is valid for two years. Criminal record checks are needed for directors, the CEO, the president and everyone who owns or controls 20 percent or more; each check must be no older than six months. Any change to the information must be reported to FINTRAC within 30 days. FINTRAC charges no registration fee.
- Usually, in our experience, preparing the package and the program takes 3–6 weeks, and the whole path to the registry takes 3–5 months; according to FINTRAC, most complete applications are reviewed within three months. The timeline depends on the case, its details, the work of the authorities and force majeure.
Your situation
Pick the situation closest to yours: a short note on the route and the first step.
We are launching a money transfer service, our team is from Ukraine
We incorporate a Canadian corporation, then register it with FINTRAC as an MSB for funds transfer. Ukrainian criminal record checks with certified translations are prepared in parallel with the compliance program.
Example. The founders of a transfer service for the Ukrainian diaspora opened a corporation, collected checks for three owners and filed a complete application on the first attempt.
Discuss this case →Crypto exchange or OTC desk: we need an MSB licence (FINTRAC registration)
Exchanging and transferring virtual currency is an MSB service, so you need FINTRAC registration and a compliance program covering the travel rule and large virtual currency transaction reports from 10,000 Canadian dollars.
Example. An OTC desk for corporate clients described its volumes for each service in the application and received a program with a separate risk assessment for wallets and counterparties.
Discuss this case →Payment company abroad, clients in Canada, no office there
Such a company usually falls under foreign MSB status. We check the signs of directing services at Canada, prepare the FMSB registration and find a representative for service who resides in Canada.
Example. A European payment provider launched a .ca website and advertising for Canada; before launch it registered as an FMSB.
Discuss this case →We already have a Canadian company and want to add currency exchange
A separate corporation is unnecessary: we register the existing company as an MSB, extend the compliance program to the new service and check that directors and owners meet the requirements.
Example. An importer with an Ontario corporation added currency exchange for its partners and completed FINTRAC registration before the first deal.
Discuss this case →The business will operate in Quebec
In Quebec, in addition to FINTRAC registration, you need a provincial money services licence under the Money-Services Businesses Act, administered by Revenu Québec. We prepare both packages and keep the information in them consistent.
Example. A currency exchange office in Montreal filed with FINTRAC and Revenu Québec at the same time, with identical owner information.
Discuss this case →Our registration expires soon or FINTRAC has sent a request
A business has 30 days to answer a request for clarification, and renewal is filed before the expiry date. We prepare the answer, update the information and the program, and file the renewal.
Example. A company received a FINTRAC request about its ownership structure, collected documents for the whole ownership chain in two weeks and answered on time.
Discuss this case →What turnkey FINTRAC MSB registration includes
Turnkey FINTRAC MSB registration covers the company, the FINTRAC application, the compliance program and support after you are entered in the registry. We need documents and decisions from you; correspondence with FINTRAC and preparation of the package are on us.
MSB in Canada: who must register
A money services business is a business that provides at least one money service and has a place of business in Canada: it is incorporated in Canada or has an office, employees, agents or branches there. Services on the FINTRAC list:
- foreign exchange dealing;
- money transferring, including bill payment and payment services for goods and services;
- issuing or redeeming money orders, traveller's cheques and similar instruments;
- dealing in virtual currency: exchange and transfer;
- crowdfunding platform services;
- transporting currency, money orders and traveller's cheques by armoured car, cheque cashing, and acquiring services for private ATMs.
A foreign MSB (FMSB) has no place of business in Canada but directs services at persons and entities in Canada and provides them to Canadian clients. FINTRAC sees the Canadian focus in marketing aimed at Canadians, a .ca domain and listings in Canadian directories.
Company
- Choice: a new corporation or an existing company; for a new one, company registration in Canada at the federal or provincial level.
- A federal CBCA corporation needs resident Canadian directors: at least 25 percent of the board, and at least one if there are fewer than four directors. For a team without Canadian residents we consider a provincial corporation: each province sets its own director rules.
- A document describing the ownership and control structure up to the ultimate owners.
- For an FMSB, a representative for service who resides in Canada.
FINTRAC application
- A pre-registration request, after which a FINTRAC officer contacts the company and sends the registration form.
- The form: banking details, compliance officer, number of employees, incorporation details, owners and management, every location and every agent, expected annual transaction volume for each service.
- Criminal record checks and certified translations.
- Upload through the FINTRAC secure system: the link is valid for 15 days, otherwise the application is closed.
- Answers to requests for clarification within 30 days.
Compliance program
A compliance program is mandatory for every MSB and has five elements:
- appointment of a compliance officer with the necessary authority;
- written AML/KYC policies and procedures approved by a senior officer and kept up to date;
- a documented risk assessment covering clients, services, channels and countries;
- a written training program and plan for employees and agents;
- an effectiveness review at least every two years.
In a small business the owner can be the compliance officer. In larger companies FINTRAC advises appointing someone who does not handle or transfer funds personally. Appointing an officer alone does not make a program.
Since 26 March 2026, amendments under Bill C-12 (Strengthening Canada’s Immigration System and Borders Act) to the FINTRAC penalty regime are in force: for violations after that date, maximum penalties can be up to 40 times the previous limits, and mandatory compliance agreements and FINTRAC compliance orders are introduced. That is why we write the program around your real processes from day one.
Other regimes we check
- Quebec: a provincial money services licence under the Money-Services Businesses Act, administered by Revenu Québec.
- Payment services for retail clients: registration with the Bank of Canada under the Retail Payment Activities Act.
- Ministerial directives on transactions connected with Russia, Iran and North Korea: we build them into the procedures.
After registration
- Notices to FINTRAC of changes within 30 days: new owners of 20 percent or more, directors, addresses, services.
- Renewal every two years.
- Agent checks: since 1 October 2025, an MSB screens each agent and obtains a criminal record check before working with them, then repeats the check every two years.
- Program updates, training, effectiveness review; preparation for a FINTRAC examination.
- Company bookkeeping and reporting: accounting for an international company.
For founders from Ukraine
An owner or director from Ukraine obtains the criminal record check from the authority that issues such certificates in the country of residence; if the person lives in another country, the check is needed from there. We add a certified translation into English or French. Documents on the ownership chain, including companies in Ukraine and other countries, are combined into a single structure document. Taxes are reviewed separately: a Canadian corporation pays tax in Canada, and an owner who is a Ukrainian tax resident files a CFC report under the Ukrainian CFC (controlled foreign company) rules.
Registration or a ready-made company
Some clients compare a new registration with buying a company that is already on the registry; that is a separate service, a ready-made MSB company in Canada. A purchase does not remove the checks: the company reports the change of owners and directors to FINTRAC within 30 days, and the new people must meet the same requirements as at registration. We decide which route fits after reviewing your task.
How long FINTRAC MSB registration (the MSB licence) takes
Usually, in our experience, FINTRAC MSB registration takes 3–5 months from contract to entry in the registry: 3–6 weeks of preparation plus the FINTRAC review period. The timeline depends on the case, its details, the work of the authorities and force majeure.
- Task review: 1–2 business days to define the services, client countries, MSB or FMSB status, and whether Quebec and the Bank of Canada are involved.
- Company: if there is no corporation yet, usually 1–2 weeks.
- Criminal record checks: the least predictable part of preparation, since issuing times vary by country, plus a certified translation. A check must be no older than six months on the application date, so we order it to match the filing schedule.
- Compliance program: 2–4 weeks, depending on the number of services, agents and channels.
- FINTRAC review: according to FINTRAC, most complete applications are reviewed within three months of receiving the full package; complex ones take longer.
The official FINTRAC benchmark covers only the review of a complete package. FINTRAC closes incomplete applications, and they have to be filed again. The document upload link is valid for 15 days. Each request for clarification allows 30 days, and every delay in answering extends the review.
Timelines are longer in predictable cases: a multi-level ownership structure, several services including virtual currency, agents in different provinces, a parallel Quebec licence. We name these points at the start.
After registration an MSB has its own dates: renewal before the two years run out, 30 days to report changes and to answer a request, an effectiveness review every two years. We hand over the calendar together with the program.
What FINTRAC MSB registration (the so-called MSB licence) costs
We calculate the cost of FINTRAC MSB registration individually: FINTRAC charges no registration fee, so the budget depends on the scope of work and related registrations.
- Which services and at what volume: currency exchange, transfers, virtual currency, crowdfunding.
- An MSB with a place of business in Canada or a foreign MSB with a representative.
- Whether a Quebec licence and Bank of Canada registration under the RPAA are needed.
- Whether there is a corporation or one has to be incorporated.
- The company structure and the number of owners and managers who need criminal record checks and translations.
- The depth of the compliance program: number of channels, agents, client countries.
- Bank and payment accounts, bookkeeping, support after registration.
Government fees of other registrars, for example for incorporation or a Quebec licence, are listed separately in the estimate. Describe your task in a few sentences and we will estimate the work within a business day. For a detailed review there is a 30-minute consultation for 100 euros.
Why clients trust us with FINTRAC MSB registration
Five reasons founders of payment, exchange and crypto projects go through FINTRAC registration with us.
In business since 2012
We work in 50+ jurisdictions; we know the requirements of registrars, banks, tax authorities and financial regulators from our own cases.
FINTRAC, registrars and banks are on us
Correspondence with FINTRAC, Corporations Canada and the bank and answers to their requests are our job. We need documents and decisions from you.
We carry the case to the result
If FINTRAC, a registrar or a bank sends remarks, we rework them at no extra charge.
One team for the whole structure
Corporation, MSB registration, compliance program, account, bookkeeping, taxes and the Ukrainian CFC rules, with no need to look for separate contractors.
Contract and confidentiality
We work under a contract, and the confidentiality terms are written into it.
How to get an MSB licence in Canada (FINTRAC registration): our process
Getting an MSB licence in Canada, that is FINTRAC registration, takes six steps, and at each one you know what is needed from you.
- Task review. We define the services, MSB or FMSB status, whether a Quebec licence and Bank of Canada registration are needed, and whether to use a new or an existing company.
- Company and structure. We incorporate a corporation or prepare an existing one, draw up the ownership structure document and, for an FMSB, appoint a representative in Canada.
- Checks and documents. We order criminal record checks for owners of 20 percent or more and management, certified translations and corporate documents.
- Compliance program. We appoint the compliance officer and write the AML/KYC policies, risk assessment and training plan.
- FINTRAC application. We file the pre-registration request, complete the form, upload the package through the secure link and answer requests.
- Registry and support. After entry in the registry we handle change notices, renewal, training and reviews.
Documents for FINTRAC registration
FINTRAC registration requires corporate documents, criminal record checks for key people and information about the future MSB operations; the exact list depends on the services and the structure.
About the company
- Certificate of incorporation or a recent corporate profile with the name, address and directors.
- A document describing the ownership and control structure.
- Banking details, if an account already exists.
- Addresses of all locations and information about agents.
- For an FMSB, details of the representative for service in Canada.
About the people
- Names and dates of birth of the owners and senior management.
- Criminal record checks for the CEO, the president, directors and everyone who directly or indirectly owns or controls 20 percent or more.
- The check is issued by the competent authority of the country of residence and must be no older than six months before the application. For residents of Ukraine it is a certificate from the Ukrainian authority that issues such documents.
- If the check is not in English or French, a translation by a certified translator with a certification statement, obtained before filing.
About the business
- The list of MSB services and an estimate of the annual transaction volume in dollars for each service.
- Number of employees.
- Compliance officer details.
- The compliance program: policies, risk assessment, training plan.
What you receive
- The FINTRAC registration notice and an entry in the public MSB Registry with a registration number and expiry date.
- A compliance program with policies, risk assessment and training plan.
- The company's corporate documents.
- A calendar for renewal, notices and effectiveness reviews.
Reference: MSB and foreign MSB (FMSB)
Status depends on the place of business: a company with a presence in Canada registers as an MSB, and a company without one but with Canadian clients registers as a foreign MSB.
| Criterion | MSB | Foreign MSB |
|---|---|---|
| Place of business in Canada | Yes: Canadian corporation, office, employees, agents or branches | No |
| Clients | Any | Services directed at and provided to persons and entities in Canada |
| Representative in Canada | Not required | Agent for service who resides in Canada |
| When to register | Before starting operations | Before starting operations |
| Registration term | Two years, renewable | Two years, renewable |
| Changes to information | Notice within 30 days | Notice within 30 days; without updated representative details FINTRAC refuses or revokes the registration |
A provincial registration or licence does not replace FINTRAC registration.
Reference: MSB reports to FINTRAC
An MSB submits suspicious and large transaction reports to FINTRAC; the threshold for large transactions is 10,000 Canadian dollars, and suspicious transactions have no threshold.
| Report | When required | Deadline |
|---|---|---|
| Suspicious transaction report, STR | There are reasonable grounds to suspect a link to money laundering or terrorist financing, regardless of the amount | As soon as practicable after completing the measures that establish the grounds |
| Listed person property report | The MSB holds property of a person or entity on a sanctions or terrorist list that the law requires it to report | Immediately |
| Large cash transaction report | 10,000 Canadian dollars or more received in cash in a single transaction, applying the 24-hour rule | 15 calendar days |
| Large virtual currency transaction report | 10,000 Canadian dollars or more received in virtual currency, applying the 24-hour rule | 5 business days |
| International electronic funds transfer report | An international transfer of 10,000 Canadian dollars or more sent or finally received, applying the 24-hour rule | 5 business days |
Beyond reports, an MSB identifies clients, determines beneficial owners and politically exposed persons, monitors business relationships, keeps records and passes originator and beneficiary information along with transfers, including virtual currency transfers. Ministerial directives set special measures for transactions connected with Russia, Iran and North Korea; for clients from Ukraine and the region this is part of daily counterparty screening.
Reference: FINTRAC, Revenu Québec and the Bank of Canada
A payment or exchange business in Canada can fall under three regimes at once, each run by its own regulator.
| Regulator | Law | What it regulates | Form of authorisation |
|---|---|---|---|
| FINTRAC | Proceeds of Crime (Money Laundering) and Terrorist Financing Act | Anti-money laundering and anti-terrorist financing in all MSBs and FMSBs | Registration in the MSB Registry for two years |
| Revenu Québec | Money-Services Businesses Act | Money services for a fee in Quebec: currency exchange, funds transfers, issuing and redeeming traveller's cheques, money orders and bank drafts, cheque cashing, ATMs, crypto ATMs | A licence of the relevant class for each service; when an application is filed, the Minister notifies the Sûreté du Québec and the local police |
| Bank of Canada | Retail Payment Activities Act | Retail payment functions of payment service providers | Registration in the PSP registry; a one-time application fee and annual assessments |
At the start we check which of the three regimes apply to your model and prepare the packages so that the information in them matches.
Reference: refusal and revocation of MSB registration
FINTRAC refuses or revokes a registration if the company or its key people do not meet the requirements of the law or the company fails to meet its obligations to FINTRAC.
- Ineligible persons. Persons under certain sanctions, persons on terrorist lists, and persons convicted of money laundering, terrorist financing and a number of Criminal Code offences, including equivalent foreign convictions, cannot own or manage an MSB.
- Corporation. A company cannot register if its CEO, president, director or owner of 20 percent or more is on terrorist lists or has been convicted of certain offences.
- Unpaid penalty. This also covers persons who have not paid an administrative monetary penalty 30 days after the proceedings ended.
- Revocation on the facts. If a registered business becomes ineligible, its registration is revoked from that day.
- Requests and examinations. Grounds for refusal or revocation include silence on a request for clarification for more than 30 days or refusal to cooperate with a FINTRAC examination.
- Renewal. A registration that was not renewed by its expiry date is considered expired.
FINTRAC communicates its decision in writing with reasons. Within 30 days of receiving the decision you can ask the FINTRAC Director to review it, and the Director's decision can be appealed to the Federal Court. That is why we check the people in the structure before filing.
How to start
Describe your task in a few sentences: which services, where your clients are, who the owners are and whether you have a company in Canada. We reply within a business day, and on a free 10-minute call we tell you whether you need MSB or FMSB status and what else is required.
Other services
Sources
FINTRAC — Money services businesses (who is an MSB and FMSB, obligations); FINTRAC — Register a money services business; FINTRAC — Maintain your registration (requests, renewal, three months); FINTRAC — MSB Registry (registration is not a licence); Bank of Canada — Retail payments supervision (RPAA, PSP registration, fees); FINTRAC — Compliance program requirements; FINTRAC — Ministerial directives; FINTRAC — Changes to the AMP framework, Bill C-12; Justice Laws — Proceeds of Crime (Money Laundering) and Terrorist Financing Act; LégisQuébec — Money-Services Businesses Act, CQLR c. E-12.000001. Checked: 27.09.2026.
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Frequently asked questions
MSB license Canada: what does it actually mean?
Who needs MSB registration in Canada?
Can I get an MSB license in Canada without an office in Canada?
How long does FINTRAC MSB registration take?
Is there a fee for FINTRAC registration?
Who needs a criminal record check?
Do we need a compliance officer?
Do you guarantee FINTRAC registration?
What should we do if FINTRAC sends a request for clarification?
Do we need a Quebec licence in addition to FINTRAC registration?
Which is better: registering an MSB company in Canada or buying a ready-made one?
How much does an MSB licence in Canada cost?
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