Before entering the market, entrepreneurs should determine which federal rules apply to their planned operations. The term MSB permit in Canada is commonly used in online searches, although FINTRAC operates a registration system rather than issuing a separate permission. A business may also need to register with the Bank of Canada as a PSP under the RPAA. These are separate regimes, and some businesses may fall under both.
What Does It Cover?
| Category | Examples of covered operations |
| Currency exchange | Exchanging one currency for another |
| Money transfers | Sending or transmitting funds |
| Cryptocurrency | Dealing in virtual currencies where federal rules apply |
| Money orders | Issuing or redeeming money orders and certain similar instruments |
| Cheque cashing | Cashing eligible cheques |
| Other covered categories | Certain crowdfunding platforms, private automated banking machine acquirer operations, and currency transportation |
| RPAA-covered payment functions | Providing or maintaining accounts, holding end-user funds, initiating electronic funds transfers, transmitting payment instructions, and facilitating payment clearing or settlement, where the RPAA applies |
FINTRAC enrollment addresses AML and CTF obligations. The RPAA regime covers qualifying retail payment functions and introduces separate operational risk and end-user fund safeguarding obligations. A business must assess each regime independently, as registration with one authority does not replace enrollment with the other.
Benefits
For eligible businesses, the local market offers a clear starting point for establishing money-related operations.
- Access to local customers. Completing the applicable federal procedure helps a business meet an essential condition for providing covered services here.
- A defined regulatory position. FINTRAC’s rules establish expectations for customer identification, record retention, and the handling of suspicious or reportable transactions.
- Stronger commercial credibility. FINTRAC registration allows banks, payment providers and business partners to verify a company’s registration status in the public MSB Registry. However, registration does not constitute regulatory endorsement and does not guarantee bank account opening, payment processing arrangements or access to financial infrastructure.
- Options for foreign operators. Eligible businesses based abroad may serve Canadian customers without necessarily opening a physical office in the country.
- No federal filing fee. FINTRAC does not charge for MSB enrollment. Professional assistance, corporate arrangements, and the preparation of internal policies may still involve costs.
These points should be assessed against the proposed operating model. The appropriate route depends on the services offered and the additional rules that may apply.
Key Criteria in 2026
The information requested by FINTRAC depends on the business’s legal form, location, management, and planned operations. Preparation generally involves the following areas.
Corporate details and management
The business must provide information confirming its existence and governance. For a corporation, this includes incorporation records and information explaining how the entity is controlled.
Details about directors, senior officers, individuals with significant ownership or control, locations, employees, and agents may also be needed. FINTRAC requests estimates of expected annual transaction volumes for each relevant service category.
Background Checks for Criminal Records
Checks are required for specified senior officers, directors, and individuals who directly or indirectly own or control at least 20% of the entity. Sole proprietors must provide the applicable check for themselves.
The checks must come from an authorised source in the relevant country and generally must be issued no more than six months before submission. If a check is not in English or French, a certified translation is required.
Compliance measures within the company
An MSB has to develop a programme that deals with both money laundering and terrorist financing. Main components of the programme include:
- appointing a compliance officer;
- assessing and documenting risks relevant to the organisation;
- putting in place policies and procedures in writing;
- training employees;
- writing to the prescribed intervals about the programme`s progress.
Such a programme has to be consistent with the way of doing business that is reflected in the actual business operations. It should not rely entirely on generic solutions that do not take into account the company`s real situation.
Customers checks and keeping of records
Depending on the service and transaction, the business may need to verify customer identities, establish beneficial ownership, maintain prescribed records, and monitor business relationships.
Reporting duties can include large cash transaction reports, large virtual currency transaction reports, and electronic funds transfer reports. The applicable thresholds and conditions depend on the type of transaction.
The conditions which the foreign MSB has to accept
A FMSB must appoint a representative for service who resides in Canada and is authorised to receive FINTRAC-related notices and inquiries on behalf of the company. Canadian citizenship is not required.
The appointment of a representative for service does not transfer the FMSB’s regulatory obligations or liability to that representative. The foreign business remains responsible for complying with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations.
Bank of Canada PSP Registration under the RPAA
Businesses performing retail payment activities within the scope of the RPAA must register with the Bank of Canada. This requirement applies to local PSPs and foreign PSPs that direct and provide covered payment services to end users in Canada, subject to statutory exclusions.
Key obligations include:
- Providing details about the business and its operations;
- Maintaining operational risk and incident response procedures;
- Protecting end-user funds where applicable;
- Reporting relevant incidents and changes;
- Filing an annual report by March 31.
This process is separate from FINTRAC MSB/FMSB registration. Businesses covered by both regimes must meet the rules of each. PSPs must obtain the required approval before starting covered operations.
How to Get an MSB License in Canada
The process begins with identifying the correct category and preparing the information FINTRAC expects. Missing or unclear information can lead to delays or a request to submit a complete set again.
- Identify the applicable category.
- Gather the corporate information.
- Prepare the internal programme.
- Complete the FINTRAC pre-registration form.
- Submit the full set of information.
- Maintain the required status.
- Apply to the Bank of Canada if the RPAA applies.
- Maintain both registrations where applicable.
Our Assistance
Eternity Law International assists entrepreneurs in assessing the local regulatory position and preparing for market entry.
Depending on the scope of the engagement, our assistance can include:
- Initial assessment;
- Corporate preparation;
- Policy development;
- FINTRAC submission;
- PSP enrollment guidance;
- Ongoing guidance.
The appropriate scope depends on the business’s circumstances and planned operations.
Contact Eternity Law International to discuss your plans and establish the appropriate route for operating. Also look at the information about forex brokerage and ready-made entities.
FAQ
Is an MSB license required in Canada?
Businesses covered by the federal MSB rules must register with FINTRAC before beginning the relevant operations. Additional authorisations may apply depending on the nature of the business.
Does FINTRAC issue an MSB permit?
No. FINTRAC maintains a register of money services businesses but does not issue an MSB licence or a certificate of registration. The commonly used search term refers to the federal registration procedure.
How much does MSB registration cost?
FINTRAC charges no federal fee. The overall budget may include professional assistance, corporate establishment, translations, and the preparation of internal policies.
How long does the process take?
FINTRAC states that most complete submissions are processed within approximately three months. Additional questions or incomplete information may extend the timeline.
What does the RPAA require from a PSP?
Depending on its operations, a PSP must maintain an operational risk and incident response framework, safeguard end-user funds it holds, report applicable incidents and changes, and submit annual reports to the Bank of Canada.
