Maksym Stepanenko
Managing Partner, Crystal Tax
International client projects since 2012: company structures, tax, immigration, DUNS and NCAGE. 50+ jurisdictions.
In Canada, a money services business registers with FINTRAC before it begins to operate, and this registration is what people usually call an MSB license. In Québec the business also needs a provincial licence.
Since 2012 · MSB and foreign MSB · FINTRAC registration and compliance program in one team · FINTRAC charges no registration fee
In brief
FINTRAC treats you as a money services business if you offer at least one MSB service and have a place of business in Canada, that is, you are incorporated in Canada, have a physical location in Canada, or have employees, agents or branches in Canada. MSB services include:
A foreign money services business provides at least one of these services, has no place of business in Canada, and directs and provides the services to persons or entities in Canada. It registers with FINTRAC too.
Section 11.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires MSBs and foreign MSBs to register with FINTRAC. The process starts with the pre-registration form; a FINTRAC compliance officer then contacts the applicant and provides the registration form. The application includes:
Criminal record checks are required for the chief executive officer, the president, the directors and each person who owns or controls, directly or indirectly, 20% or more of the entity or its shares. Each check must be issued no more than 6 months before the application, and a document in a language other than English or French must be translated and attested by a certified translator.
Corporate documents. A corporation provides a certificate of incorporation, or another current record showing its name, address and directors, and a document setting out its ownership, control and structure. Documents go through the link from FINTRAC's Secure Document Transfer System or a Canada Post Connect message that the FINTRAC compliance officer provides during registration. The Secure Document Transfer System link expires within 15 days.
Timing. FINTRAC states that the majority of complete applications are processed within three months from receipt of a complete package, and complex applications may take longer.
Section 11.11 of the Act lists persons and entities that are not eligible for registration, including those subject to sanctions under the United Nations Act or the Special Economic Measures Act, listed terrorist entities under the Criminal Code, and persons convicted of the offences listed in that section, such as money laundering and terrorist financing offences.
A registered MSB is a reporting entity and keeps a compliance program with these elements:
Registration is renewed every two years (section 11.19 of the Act). Any change to the information in the application is reported to FINTRAC within 30 days after the business becomes aware of it (section 11.13).
Québec's Money-Services Businesses Act applies to anyone operating a money-services business for remuneration in the province. It covers currency exchange, funds transfer, traveller's cheques, money orders and bank drafts, cheque cashing, automated teller machines and cryptoasset automated teller machines. Under section 3 such a business must hold a licence of the appropriate class, and under section 4 licences are issued by the Minister. The application is filed with the fee set by regulation by the business's respondent. The respondent must be 18 or older, resident in Québec and not under tutorship or a protection mandate, must be a director, officer or partner of the business and must meet any other condition set by regulation. A business that is not constituted under Québec law and has no head office or establishment in Québec may designate a respondent who is not a director, officer or partner, provided that person can properly exercise a respondent's functions with the Minister (section 5). The Québec licence is in addition to FINTRAC registration.
Knowingly contravening the registration requirement of section 11.1 is an offence under section 74 of the Act: on summary conviction, a fine of up to $2,500,000 or imprisonment of up to two years less a day, or both; on indictment, a fine of up to $5,000,000 or imprisonment of up to five years, or both. FINTRAC can also issue administrative monetary penalties to reporting entities that do not comply.
There are two ways to obtain what the market calls a Canadian MSB license:
FINTRAC: Register your MSB or FMSB; FINTRAC: Money services businesses; FINTRAC: Compliance program requirements; Proceeds of Crime (Money Laundering) and Terrorist Financing Act, S.C. 2000, c. 17; Québec Money-Services Businesses Act, CQLR c E-12.000001. Material checked and updated on 07.10.2026.
Maksym Stepanenko
Managing Partner, Crystal Tax
International client projects since 2012: company structures, tax, immigration, DUNS and NCAGE. 50+ jurisdictions.
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