When someone says “follow the money,” regulators do that exactly. If your business moves, exchanges, or transfers money for clients, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) wants to know about you through the money services business registration (MSB registration). While registration itself is free, what it takes to stay on the right side of the law, however, goes well beyond filling out a form.
What is money services business registration?
Money services business registration is a federal requirement under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). It brings non-bank businesses that provide financial services to the public into Canada’s anti-money laundering and anti-terrorist financing framework, administered by FINTRAC.
Two points are worth getting straight from the start:
- this is not a licence, as FINTRAC does not issue licences or certificates of any kind
- registration signals only that a business has met the legal requirements to register
The PCMLTFA is also the statute that created FINTRAC itself, giving it a mandate to detect and prevent money laundering and the financing of terrorist activities.
What services trigger MSB registration
Under the PCMLTFA, a business becomes a money services business when it provides at least one of the following:
- foreign exchange dealing
- remitting or transmitting funds, including through informal networks (e.g., Hawala or Hundi)
- issuing or redeeming money orders, traveller’s cheques, or similar negotiable instruments
- dealing in virtual currency, including exchange and transfer services
- crowdfunding platform services
- armoured car transport of currency or negotiable instruments
- cheque cashing
- acquirer services for private automated banking machines
Whether lawyers are included in the MSB registration
Generally, lawyers are not covered under the money services business registration. In Canada (Attorney General) v. Federation of Law Societies of Canada, 2015 SCC 7, the Supreme Court of Canada struck down the PCMLTFA provisions that would have brought the legal profession into this registration and inspection scheme.
The Court held that the PCMLTFA provisions violated the Canadian Charter of Rights and Freedoms, specifically:
- s. 7 by compromising counsel’s duty of commitment to the client
- s. 8 by failing to adequately protect solicitor-client privilege
John Hunter, QC of Hunter Litigation Chambers, and Roy Millen of Blake, Cassels & Graydon LLP acted for the Federation of Law Societies of Canada (FLSC).
Watch this video to learn more about the money services business registration:
Learn more about the PCMLTFA and the FINTRAC by bookmarking our Special Edition on Technology Law for more news and updates.
Who needs to register with the FINTRAC?
There are two categories of businesses that must register with the MSB or the FINTRAC:
- domestic money services businesses
- foreign money services businesses (FMSBs)
We’ll discuss these two below.
Domestic MSBs
A business qualifies as a domestic MSB when:
- it offers at least one triggering service, and
- it has a place of business in Canada
That presence does not require a head office, since having employees, agents, or a single branch in the Canada is enough.
Foreign MSBs
A business qualifies as an FMSB when it:
- has no place of business in Canada,
- provides at least one qualifying service,
- directs those services at persons or entities in Canada, and
- actually serves clients with ties to Canada, such as a Canadian address, Canadian-issued identification, or a Canadian banking relationship
Many international fintechs and remittance companies discover the FMSB requirement only when a bank or payment partner asks for their MSB registration number before opening an account. In other words, the obligation does not wait for physical presence in the country.
Who is not covered by the MSB registration
If you deliver qualifying services strictly as an agent for a registered MSB, the registration obligation belongs to that MSB, and not to you.
Who is barred from registering
Certain individuals and entities cannot register at all, including:
- convicted of money laundering or terrorist financing offences under the Criminal Code
- corporations whose directors or 20-percent-or-more owners carry the same convictions
- persons listed under Canadian sanctions legislation
More about money services business registration with this video:
Head over to our list of the best technology transactions in Canada as ranked by Lexpert if you need help with your MSB registration.
How much does MSB registration cost in Canada?
The FINTRAC registration itself costs nothing. There is no application fee, no licensing charge, and no annual government levy.
Anyone charging a fee to submit a FINTRAC application on your behalf should raise a red flag. Fee-for-registration scams targeting MSB applicants are a known fraud vector, as per the FINTRAC.
On the other hand, the real expenses may come from establishing the legal entity and building the compliance program that must comply with the MSB registration.
How long does MSB registration take
- Ontario entity registration: approximately five to seven business days
- FINTRAC MSB registration: approximately two to four months from receipt of a complete application
Renewal of MSB registration
A money services business registration is valid for two years. Businesses must apply to renew before the expiry date. If a renewal application is submitted on time, the business stays registered while FINTRAC processes it.
What happens if you operate without registering with FINTRAC?
Operating as an unregistered money services business is a violation and a statutory offence under the PCMLTFA. It may result in imprisonment, administrative penalties, among others.
Criminal charges
The PCMLTFA creates offences for operating without registration and for providing false information during the registration process. These are not administrative irregularities, and they are statutory offences that can lead to prosecution.
Administrative monetary penalties
Separate from criminal prosecution, FINTRAC has the authority to issue administrative monetary penalties (AMPs) for non-compliance.
As of March 26, 2026, FINTRAC’s updated AMP framework allows maximum penalties of up to 40 times the previous limits, and FINTRAC can now also issue compliance agreements and compliance orders.
For instance, the Exchange Bank of Canada was fined $2.4 million for PCMLTFA violations, illustrating the real-world scale of these consequences.
Public naming
FINTRAC publishes the names of penalised entities on its website. Reputational exposure compounds any financial penalty.
Revocation and appeals
Businesses whose registrations are denied or revoked have 30 days to request a review of that decision. Grounds for revocation include:
- failing to answer a FINTRAC clarification request within 30 days
- failing to notify FINTRAC of changes to operating information
- being found ineligible for registration
Money services business registration: where the trail begins
Following the money in Canada’s regulatory landscape leads to FINTRAC, sooner or later. Whether you run a crypto exchange, a remittance service, or a foreign exchange desk, the starting point is the same: determine whether your services bring you within the money services business framework, and if they do, register before you take your first client. A lawyer who practises in financial services or technology law can help you get that answer quickly.
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