MSB license in Canada

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Before approaching FINTRAC, a business normally needs a properly incorporated Canadian legal entity. For licensing purposes, the recommended default vehicle is the Business Corporation (Inc./Ltd./Corp.) — Canada's closest equivalent to an internationally recognized private limited liability company — incorporated federally through Corporations Canada, the registry branch of Innovation, Science and Economic Development Canada. Other legal forms (unlimited liability companies, partnerships, cooperatives, extra-provincial registrations, etc.) are also available in Canada, but the Business Corporation is the simplest and most broadly suitable default for an MSB applicant (see the Basic company reference for the full list of forms).

Key confirmed points from the registrar:

• Filings (incorporation and post-incorporation changes such as annual returns, and changes to directors, registered office, or name) can be submitted electronically through Corporations Canada's Online Filing Centre.
• A corporate name is chosen as either a word name or a numbered name.
• A federally incorporated company must additionally register extra-provincially in every province or territory where it actually carries on business.
• The company must create and maintain an individuals with significant control (ISC) register, recording specified information about persons who control the corporation.
• For opening a corporate bank account, founders/directors/beneficial owners should expect standard identification requirements consistent with Canada's AML framework under the PCMLTFA. Major Canadian banks include TD Bank, Scotiabank, and CIBC.

Canada's MSB regime is administered by FINTRAC under the PCMLTFA and its associated Regulations. You are considered an MSB if you offer at least one designated MSB service — 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; or acquirer services for private automated banking machines — and you have a place of business in Canada (incorporated in Canada, a physical location, or employees/agents/branches in Canada).

A Foreign Money Services Business (FMSB) is a business that offers at least one MSB service, has no place of business in Canada, but directs its services at persons or entities in Canada (for example through Canada-targeted marketing, a '.ca' domain, or listing in a Canadian business directory) and serves clients with a Canadian address, Canadian-issued ID, or Canadian-based banking/payment processing.

Core obligations for registered MSBs/FMSBs include:

• Registering with FINTRAC (registration is renewed every 2 years)
• Ongoing transaction reporting
• Record keeping
• Client identification (know-your-client procedures)
• Maintaining a compliance program

Certain persons and entities are ineligible to register as an MSB or to act as an agent/mandatary of one — including those convicted of money laundering, terrorist financing, or specified other offences; corporations/partnerships whose leadership or 20%+ owners are ineligible; and persons or groups listed under the Criminal Code or the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.

Businesses can first confirm whether registration is required using FINTRAC's online questionnaire, which returns one of three outcomes: no registration needed, MSB registration needed, or FMSB registration needed.

It is worth noting that adjacent, separately administered regimes can also apply depending on the business model: payment service providers (e.g., digital-wallet and online-payment operators) may additionally need to register with the Bank of Canada under the Retail Payment Activities Act, and crypto-asset trading platforms or dealer-like/custody structures may trigger separate requirements from provincial/territorial securities regulators coordinated through the Canadian Securities Administrators. These are distinct regimes from FINTRAC MSB registration and should be assessed alongside it where relevant.

Registered MSBs and FMSBs must maintain an ongoing compliance program as one of their core statutory obligations under the PCMLTFA, alongside record keeping and client identification — meaning the business needs an internal function responsible for compliance, reporting, and record-keeping on a continuing basis.

Businesses that deal in foreign exchange, remit or transmit funds, deal in virtual currency, operate crowdfunding platforms, or provide other designated payment services in or into Canada generally must register as a Money Services Business (MSB) — or, if based outside Canada but serving Canadian clients, as a Foreign Money Services Business (FMSB) — with FINTRAC, Canada's federal financial-intelligence and AML/CTF regulator. This is officially a registration regime rather than a discretionary licence, carried out under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and it is the recognized Canadian equivalent of what other jurisdictions call an MSB or payment-services licence.

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• Basic — EUR 7,500: entry-level package for Canada MSB (Money Services Business) registration, suited to straightforward cases and clients seeking the most cost-efficient route to FINTRAC registration.
• Standard — EUR 14,000: mid-tier package offering a broader level of support than the Basic tier for clients with somewhat more involved requirements.
• Premium — EUR 29,000: the most comprehensive package for Canada MSB registration, for clients seeking the highest level of support and attention available at this jurisdiction.

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• Financial Transactions and Reports Analysis Centre of Canada
• Bank of Canada
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act