Complete Guide to MSB Registration with FINTRAC in 2025

What Is FINTRAC and Why MSB Registration Is Mandatory

Money services businesses (MSBs) in Canada are legally required to register with FINTRAC (the Financial Transactions and Reports Analysis Centre of Canada) before starting operations. FINTRAC is Canada’s financial intelligence unit, tasked with detecting and preventing money laundering and terrorist financing. Under the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), any person or entity offering MSB services (such as currency exchange, money transfers, issuing or redeeming money orders, or dealing in virtual/crypto currencies) must register with FINTRAC. This applies even if you hold a provincial money services license or operate from outside Canada but serve Canadian clients.

Registering as an MSB is not just a formality – operating unregistered is illegal. Without FINTRAC registration, a fintech or crypto business risks serious consequences, including:

Banks closing your accounts or denying services
Hefty fines (administrative penalties up to $500,000)
Potential criminal charges for non-compliance
Being publicly listed in FINTRAC’s enforcement reports (harming your reputation)

In short, MSB registration is mandatory to establish a legal, credible fintech or crypto venture in Canada. FINTRAC registration (often informally called an “MSB license”) serves as your gateway to compliant operations, banking partnerships, and long-term viability in the Canadian market. Note: Certain individuals or entities cannot register (for example, those with money laundering or fraud convictions), so ensure all owners and directors are eligible before proceeding.

2025 Update: FINTRAC’s New Pre-Registration Stage

Important new development for 2025: FINTRAC has introduced a two-stage MSB registration process, starting with a pre-registration stage. In the past, businesses could directly submit an online MSB registration form. Now, you first submit a Pre-Registration Form to FINTRAC, after which a compliance officer will contact you with the full registration application. This pre-registration step was implemented to manage the surge in applications and ensure applicants meet basic criteria before proceeding.

How the pre-registration works: You fill out an online “Request to Register a Money Services Business” form with preliminary information about your business (e.g. contact details, intended services, basic business model description). FINTRAC’s team will review this initial submission to determine your eligibility and clarify your business model. Tip: Provide as much detail as possible about your planned services and how your business will operate. FINTRAC uses this info to ensure you genuinely require MSB registration and to assign the appropriate process. Vague or minimal answers can lead to follow-up questions and delays.

After reviewing your pre-registration, a FINTRAC compliance officer will reach out (usually by phone or email) to either provide you with login credentials for the full MSB Registration system or to request additional information. Once you receive the go-ahead (i.e. a username and password for FINTRAC’s secure registration portal or Canada Post secure link), you can move on to completing the detailed application in Stage Two. The introduction of this pre-registration stage helps FINTRAC filter out ineligible submissions and guide serious applicants through the process more efficiently.

Step-by-Step FINTRAC MSB Registration Process

Launching a fintech or crypto MSB in Canada involves several steps – from setting up your company to obtaining the official MSB registration number. Below is a step-by-step guide covering both the preparatory steps and the FINTRAC registration stages:

Step 1: Incorporate a Canadian Company

The first step is to incorporate your business in Canada (or register your legal entity). FINTRAC MSB registration is tied to a legal person (corporation, sole proprietorship, partnership, etc.), so you need a formal business entity. Most fintech entrepreneurs choose to incorporate a federal or provincial corporation. Incorporation provides you with a certificate of incorporation and other formation documents that FINTRAC will require as proof of your business’s existence and structure. Ensure your company name meets requirements (generally two parts, including a distinctive element and a descriptive element reflecting your business activity). Having a Canadian company also makes it easier to open a local bank account and demonstrates a legitimate presence in Canada.

Tip: You’ll need a Canadian address for your registered office (a physical office is not required at registration, but a legal registered address in Canada is). If you’re an international founder, consider using services for a virtual office or registered address through providers like MapleBiz. Once incorporated, maintain copies of your Articles of Incorporation, corporate by-laws, and share register – you will later submit documents that disclose your company’s ownership and governance structure.

Step 2: Obtain a Business Number and Basic Setup

After incorporation, register for a Business Number (BN) with the Canada Revenue Agency. Typically, corporations are assigned a BN upon incorporation. This number is used for tax and other federal registrations and will identify your business in FINTRAC’s records too. While FINTRAC’s forms don’t explicitly ask for your BN, having it is important for general compliance and banking.

Use this phase to also take care of basic business setup: open a business bank account (if possible) and set up channels you’ll use (website domain, etc.). Bank account information is one of the items FINTRAC asks for during registration. Some banks in Canada require your FINTRAC MSB registration before fully activating an account (due to risk policies), but you can often start the account opening process or use fintech alternatives. If you already have a bank account, prepare the bank’s name and account details for the FINTRAC form. If not, be ready to explain how you plan to handle client funds.

Lastly, ensure you have identified all owners, directors, and senior management of your company, since you’ll need their personal details and background documents in the application. Anyone with 20% or more ownership (directly or indirectly) will be subject to additional scrutiny (e.g. mandatory criminal record checks).

Step 3: Prepare All Required Documents and Information

Before you officially apply, gather the key documents and data you’ll need. FINTRAC’s registration process in 2025 asks for a comprehensive set of information about your business. Prepare the following:

Ownership and Management Details: A list of all directors, senior officers, and owners (direct or indirect) of 20% or more of the company, including full names, dates of birth, and titles. You will need to obtain criminal record checks for each of these individuals. The criminal background checks must be issued by a police or authorized agency in the person’s country of residence, dated within 6 months of your application. (If any are in a language other than English or French, have them translated and certified.) Be prepared to upload or send these as part of your application package.
Business Incorporation and Structure Documents: If a corporation, your Certificate of Incorporation and a document outlining the ownership and control structure (this could be an organizational chart or official register showing shareholders and percentages) are required. Partnerships or other entities should provide their partnership agreement or formation document plus a ownership structure chart. Essentially, FINTRAC must see proof of your business’s legal existence and who ultimately controls it.
Compliance Program Documentation: By law, every MSB must implement an Anti-Money Laundering (AML) and Counter-Terrorist Financing program at the time of registration. You should appoint a Compliance Officer (an individual responsible for the MSB’s compliance day-to-day) and have a written compliance program ready. This program should include your company’s AML policies and procedures (covering how you will verify customer identity, monitor transactions, keep records, report suspicious or large transactions, etc.), a documented Risk Assessment of your business’s exposure to financial crime risks, and a training plan for staff. FINTRAC may not ask to see the full policy manual at registration time, but having a robust compliance program is essential – regulators can ask questions or request evidence of it during the review. Ensure your program names your compliance officer and addresses Know Your Client (KYC) procedures and ongoing training commitments.
Forecasted Transaction Volumes: FINTRAC will require an estimate of the total dollar amount of transactions per year for each MSB service you plan to offer. In practice, this means you should project how much volume (in CAD) you expect to transact annually in each category (e.g. foreign exchange, money transfers, crypto trades, etc.). Prepare a reasonable forecast based on your business plan. This can be a simple number or range for each service, but it should align with your business model (FINTRAC uses this to gauge the scale of your operations).
Other Business Details: You’ll also need to provide the number of employees in your business (even if it’s just the founders initially), and detailed information on every physical location where the MSB will carry out activities. If you will have any agents or mandataries delivering services on your behalf, you must list them and be prepared to provide details and ensure they’re eligible (agents themselves must not be ineligible persons). Most startups won’t use agents initially, but if you plan to use a white-label partner or independent brokers, note this requirement.

Having all these documents and information ready in advance will make the application process smoother. Scan documents into clear PDFs (FINTRAC recommends combining related documents into one PDF) and ensure they are legible, as unclear copies will be rejected.

Step 4: Submit the FINTRAC Pre-Registration Form

With your groundwork laid, it’s time to engage FINTRAC by submitting the Pre-Registration Form (Stage 1 of the process). This form is available on FINTRAC’s website and is essentially a request to register your MSB. In the pre-registration, you will enter: your business name and contact info, the type of MSB services you intend to offer (e.g. “payment service provider” which covers transfers, or foreign exchange, or virtual currency dealer – select all that apply), and a free-form “additional information” section to describe your business model.

Be thorough and specific in this description. Explain how your business will operate, who your customers will be, how you will facilitate transactions, and how you plan to comply with AML requirements. The reason is that FINTRAC’s policy team will review this narrative closely to decide if your business indeed falls under the MSB category and if you seem prepared. If your pre-registration is too sparse or generic, FINTRAC will almost certainly follow up with emails or calls full of questions. That can add weeks or months to the process. In worst cases, if you don’t respond in a timely manner to FINTRAC’s queries during this stage, they may cancel your pre-registration request, forcing you to start over.

After you submit the form, expect a wait. As of 2025, FINTRAC has a significant backlog of applications, so the pre-registration review that once took a week can now take a few months. During this waiting period, be responsive – watch your email (including spam folder) and answer any phone calls from unknown numbers, as FINTRAC often contacts applicants from private numbers. Once FINTRAC is satisfied that you meet the basic requirements, they will confirm your eligibility and provide instructions to proceed. Typically, you will receive login credentials (username and temporary password) for FINTRAC’s secure MSB Registration online system, delivered over a phone call for security reasons. In some cases, FINTRAC may use a secure messaging service (like a Canada Post Connect link) to send you the registration form and collect documents.

Step 5: Complete the Full MSB Registration Application

Now comes Stage 2 – the full registration form. Using the credentials or link provided by the FINTRAC officer, log in to the MSB Registration system to fill out the detailed application. This form will ask for all the information you prepared in Step 3, and possibly to upload supporting documents. Key sections of the form include:

Business Identification: Legal name, any trade names, head office address, phone, email, website, etc. Also, your business number (BN) if applicable, and the type of legal entity (corporation, partnership, etc.).
MSB Activities: Specify which MSB services you will offer (foreign exchange, money transfer, issuing money orders, dealing in virtual currency, etc.) and whether you will be using agents or branches. Provide the estimated annual transaction volumes for each service type as previously prepared. Be prepared to also describe how and where these services will be offered (online, in-person, domestically, internationally, etc.).
Ownership and Control: Enter details for each owner and senior manager. The form will likely have fields for each person’s name, date of birth, title/role, ownership percentage, home address, and possibly citizenship or ID numbers. You will also declare if any owner or director has ever been convicted of financial crimes or had a prior MSB registration revoked – answering “yes” could lead to further scrutiny or ineligibility.
Compliance Officer: Provide the name and contact information of the individual you are appointing as the Compliance Officer for the MSB. This person should be someone with sufficient seniority and knowledge to oversee day-to-day AML compliance (for a small startup it could be a founder or manager with compliance training). FINTRAC requires that one be designated, so don’t leave this blank or “TBD” – that would delay approval.
Banking Information: Enter details of any business bank account you have (institution name and account number). If you have multiple accounts (e.g., one for client funds, one for operations), list them all. If you haven’t opened an account yet, you might indicate that it’s in process or which bank you intend to use. Remember, FINTRAC doesn’t require an account to approve registration, but having one strengthens your application credibility.
Upload Documents: You will need to attach the documents collected earlier – incorporation certificate, ownership structure document, and criminal record checks for the required persons. Ensure each file meets any format/size requirements and is clear to read. If the system doesn’t allow upload of certain files, the FINTRAC officer may have you send them via secure email or Canada Post secure link instead.

Double-check that all mandatory fields are filled and documents attached. The system will not let you submit if required fields are missing. Before submission, review everything for accuracy – once you formally submit the registration, you typically cannot edit the form unless FINTRAC sends it back for corrections. Errors or inconsistencies (like a name mismatch between your form and the documents) can slow down approval or trigger additional questions.

Finally, submit your registration form electronically. You should receive a confirmation that your submission was received (often an email or on-screen confirmation). At this point, your part is done, and it’s in FINTRAC’s hands to review and approve.

Step 6: Receiving Your FINTRAC MSB Registration Number

After submission, the wait resumes. FINTRAC will conduct its detailed review of your application. They may contact you for clarifications or additional information during this stage as well. For example, if something in your documents is unclear or if they have questions about your compliance arrangements, respond promptly and thoroughly to any inquiries.

Once FINTRAC is satisfied, your MSB registration will be approved. You will be notified of approval and issued a FINTRAC MSB Registration Number (often just called the MSB number). Approval typically comes via email: FINTRAC sends a notice of approval and an official registration certificate/letter in PDF format. Keep this approval letter in your records – FINTRAC does not charge any fees for registration and does not mail paper certificates, so the email PDF is your proof of registration.

Your business will also be added to FINTRAC’s public MSB Registry database, which banks and customers can search to verify that you are a registered MSB. The MSB registration number and your company name (with active status) will appear there, typically within a few days of approval.

At this point, congratulations – you are legally registered and can begin MSB operations in Canada. The MSB registration remains valid for two years from the approval date. Be mindful that registrations must be renewed every 2 years, or they will expire (more on renewal in a later section). But for now, with your FINTRAC registration in hand, you can focus on launching your product, onboarding customers, and establishing banking or payment processing relationships (most partners will ask for your MSB number as part of due diligence).

Required Documents for MSB Registration (Details)

Let’s break down the critical document categories you’ll need to have for a successful MSB registration:

Company Formation & Structure Documents: To prove your business exists and show who owns/controls it, prepare your certificate of incorporation (or equivalent registration document) and a document outlining the ownership and organizational structure. For corporations, the certificate and a list of directors/shareholders (cap table or org chart) are needed. For partnerships or sole proprietorships, provide the partnership agreement or registration and a document showing who the partners/owners are. Essentially, FINTRAC wants to see the legal identity of your entity and who is behind it. These documents must be current and authentic.
Director, Owner and UBO Information: “UBO” refers to Ultimate Beneficial Owners – individuals who ultimately own or control the business (typically anyone with ≥20–25% ownership). Gather personal details for each director, senior manager, and major owner. Government-issued ID copies aren’t always required in the application, but you should have them on hand in case FINTRAC asks. What is explicitly required are criminal record check certificates for each of the following: the CEO, the president, all directors, and each person owning 20% or more of the company. These background checks must be from a police or authorized agency, dated within 6 months of your application. If any owner/director has a criminal record relating to financial crimes, it could disqualify the registration. (For clarity: FINTRAC’s threshold for owners is 20% for registration eligibility, which is slightly stricter than the 25% threshold used for customer due diligence.) Translate any non-English/French documents and include a certified translator’s attestation.
AML Compliance Program Documents: While not always uploaded as a formal requirement, in practice you should have your AML/CFT compliance program documented and ready. This includes a written Compliance Manual or Policy detailing your procedures for client identification, record-keeping, risk assessment, transaction monitoring, reporting of suspicious transactions, etc.. FINTRAC expects every MSB to implement a compliance regime that covers all these elements, including appointing a compliance officer and scheduling regular compliance training and effectiveness reviews. It’s wise to have a Compliance Officer resume or bio on hand, showing their qualifications or experience, in case you need to demonstrate that the person is capable of the role. Note: Some applicants have been asked by FINTRAC to provide parts of their compliance program during the review, especially if the business model is high-risk (e.g. crypto exchange). A strong, well-detailed AML program that adheres to FINTRAC’s latest rules – including ongoing employee training and independent two-year effectiveness reviews – will prevent delays.
KYC, Risk Assessment and Other Supporting Docs: Alongside the formal AML policy, maintain documentation of your KYC forms or client onboarding process, and a written Risk Assessment document. FINTRAC might not ask for these at registration, but having them prepared is part of being registration-ready. For example, you should have templates for collecting client identification and a risk matrix that shows how you’ll rate client risk. These documents demonstrate you’ve internalized your obligations. Additionally, if you have any third-party agreements (say you’re using a compliance consulting firm or a white-label solution provider), have those agreements available. FINTRAC will want to know if any compliance functions are outsourced.
Bank Account Confirmation: If you have opened a bank account for your MSB, obtaining a bank letter or account statement confirming the account can be useful. FINTRAC’s form asks for bank info but doesn’t require a document for it. However, some banks require MSB registration first, and conversely, FINTRAC likes to see that you have a banking plan. If you can’t secure a bank account pre-registration, it’s not a deal-breaker, but be ready to explain your plan (e.g. using a payment processor or in-progress with a bank). For certain MSB models (like currency exchange offices), FINTRAC might expect to see at least a bank account listed, as it’s hard to operate without one. In any case, once you do get your MSB number, opening a bank account dedicated to your MSB activities will be critical.

By assembling these documents in advance, you create an application package that is complete and convincing. Missing documents or scrambling last-minute to produce them is a common cause of delays or rejections. Use the checklist in the Bonus section to ensure you have everything on file.

Estimated Timelines for MSB Registration in 2025

How long does it take to get an MSB registration in 2025? The realistic answer is: longer than it used to. In 2024, many applications were processed in about 2–3 months, but in 2025 FINTRAC has been dealing with resource constraints and a flood of new MSB applicants (especially in crypto and payments). Here’s what to expect:

Pre-Registration Review: ~2–3+ months. The initial contact from FINTRAC after you submit the pre-registration can easily take a couple of months in 2025. It used to be a matter of days, but not anymore. FINTRAC received thousands of new MSB requests, doubling the number of MSBs from 3,000 to 6,000 in a year, leading to backlogs. As a result, “pack your patience”, because the first stage that once took 5 business days now often takes several months. During this time, FINTRAC might reach out with questions, which can add a few weeks back-and-forth.
Full Application Approval: ~2–4+ months after Stage 2 submission. Once you submit the full registration form, an official decision could take a few more months. Some applications (especially very well-prepared ones) might still get lucky and be approved in as little as 4–8 weeks. However, many are seeing 5–6 months total turnaround from submission to approval in 2025. For instance, one compliance firm notes that FINTRAC is taking around 5–6 months on average to inform applicants of approval or rejection, due to thorough due diligence and internal backlogs.
Possible Delays: If FINTRAC requests additional documents mid-review (for example, updated info or clarifications), that can pause the clock. A request for more documents might come ~5 months in, and then final approval a few weeks after you satisfy the request. Security incidents (like a cyber-attack in early 2024) and increased scrutiny from international bodies (e.g. FATF) also contributed to slower processing as FINTRAC methodically checks each application.

In summary, a well-prepared MSB registration could be completed in ~3 months, but 5–6 months is not unusual in 2025. If your application has errors or requires significant back-and-forth, it could stretch longer. It’s wise to build this timeline into your launch plans so you’re not left in limbo. Engage with FINTRAC proactively and ensure your submission is complete to avoid unnecessary delays. Remember, you cannot legally operate as an MSB until approval, so plan accordingly.

On a positive note, FINTRAC does not charge any fees for registration, so the only “cost” is time and effort.

Common Mistakes to Avoid During MSB Registration

Registering as an MSB is detail-oriented. Here are common pitfalls that trip up entrepreneurs – avoid these to smooth your path:

Failing to Designate a Compliance Officer: Every MSB must appoint a compliance officer at the time of registration – someone responsible for AML compliance. A common error is either leaving this role unfilled or choosing someone without the appropriate authority/knowledge. FINTRAC expects to see a named individual and their position. Make sure you not only fill in a name, but also have that person actively engaged. Not having a compliance officer (or picking a token name with no real plan) can lead to rejection or future compliance issues.
Incomplete or Vague Pre-Registration Form: The pre-registration stage is your first impression. Submitting a form with scant details (e.g. just saying “cryptocurrency trading platform” without context) is a mistake. FINTRAC’s reviewers need clarity on your business model to determine eligibility. If you’re too vague, they will come back with questions, delaying the process or potentially cancelling your request if you don’t respond in time. Avoid generic descriptions – instead, provide a concise but thorough overview of how your service works, who your customers are, and how you’ll meet obligations. Think of it as the narrative that justifies why you need to be an MSB.
Missing or Incorrect Documentation: Another frequent mistake is not submitting all required documents or providing outdated information. Examples include forgetting to include a criminal record check for an owner, or uploading an old incorporation certificate that doesn’t show a recent name change. Firms inexperienced with MSB applications often make errors like “failing to submit your compliance program document,” “not mentioning details of your employees,” or submitting incorrect business data. Each omission will prompt FINTRAC to reach out for corrections, significantly delaying approval. Use a checklist (see below) to ensure every required piece is provided and double-check that names, addresses, and numbers are consistent across all forms and documents.
Overly General or Ambiguous Business Model Description: This is related to the pre-registration but also applies to the full application. If you use imprecise language or buzzwords without explanation (“we are a fintech platform leveraging blockchain for remittances”), you risk getting flagged for manual review. FINTRAC’s system flags applications that are vague or involve novel elements (like international crypto ownership), which then require extra scrutiny by officers. To avoid this, be straightforward and specific. Clearly state what services you provide (e.g., “a web-based currency exchange allowing users to convert CAD to USD and vice versa, up to $100k per client annually”) and how you operate. Don’t assume the reviewer will infer what your business does – spell it out to prevent misunderstandings.
Underestimating KYC and Compliance Obligations: Many startups focus on the tech or product and treat compliance as an afterthought – this is a big mistake when registering. FINTRAC wants to see that you understand your KYC, record-keeping, and reporting obligations and have plans to fulfill them. If your application or conversations with FINTRAC reveal a lack of an adequate AML program (for instance, you have “a few basic policies” only), regulators may lose confidence and either delay approval or impose conditions. Common signs of underestimating obligations include not having a detailed written program, no training plan, or ignoring the requirement for an independent two-year effectiveness review. Show that you take compliance seriously. For example, mention that you have a transaction monitoring system in mind, or that you will conduct annual training – it signals preparedness.

By sidestepping these pitfalls – appointing a qualified compliance officer, being thorough in your forms, submitting all documents, clearly describing your business, and demonstrating a solid grasp of compliance – you greatly increase your chances of a smooth and swift registration.

Ongoing Compliance After Registration

Getting your MSB registration is just the beginning. Once you have that coveted MSB number, ongoing compliance with FINTRAC and other regulations becomes part of your business as usual. Key post-registration obligations include:

Transaction Reporting to FINTRAC: As an active MSB, you must monitor transactions and report certain types to FINTRAC within prescribed deadlines. The main reports are: Suspicious Transaction Reports (STRs) – if you detect a transaction that gives reasonable grounds to suspect money laundering or terrorist financing, you must file an STR within 30 days of the suspicion. Large Cash Transaction Reports (LCTRs) – for any cash transaction of CAD $10,000 or more (or multiple smaller cash transactions that total $10k in 24 hours for the same client), file an LCTR within 15 days. Electronic Funds Transfer Reports (EFTRs) – for international electronic transfers of $10,000 or more (incoming or outgoing), report within 5 working days. Large Virtual Currency Transaction Reports (LVCTRs) – for cryptocurrency transactions equivalent to $10,000 or more received by your business, report within 5 working days. There are also Terrorist Property Reports if you ever find that you possess or control assets linked to a terrorist entity (report immediately). As an MSB, you need processes to identify these triggers and file reports via FINTRAC’s online system or API on time. Late or missed reports can lead to penalties.
Recordkeeping: You are required to keep detailed records of your transactions and client identification. Generally, any transaction of $1,000 or more, as well as any amount that requires a report, must have records kept for at least 5 years. This includes client ID records (copies of identification documents or verification references), transaction receipts/details, electronic funds transfer records, etc.. Your compliance program should specify what records are kept and how. All records should be stored securely (to protect customer privacy) and be organized in a way that you can retrieve them if FINTRAC or auditors request them. Also maintain records of your AML program documents, risk assessments, and training sessions for at least five years as well.
Ongoing AML Compliance Program: Post-registration, you must implement and maintain your AML program effectively. This means conducting the regular training for staff (document when training took place and what was covered), and performing a formal effectiveness review every two years. The effectiveness review (an internal or external audit of your AML controls) is actually mandated by regulations – it ensures you test how well your compliance program is functioning and address any gaps. If your business model changes or you introduce new products, update your risk assessment and policies accordingly.
Updating Registration Information: Your FINTRAC MSB registration isn’t static. If there are changes to your business – such as new directors or owners, a new business address, offering new MSB services, or discontinuing a service – you must update FINTRAC within 30 days of the change. This is done by filing a “Change of Registration Information” form in the FINTRAC system. Keeping your registry entry up to date is a legal requirement. Failing to report changes (for example, if you took on a new 25% shareholder and didn’t inform FINTRAC) can be considered non-compliance.
Renewal Every 2 Years: Your MSB registration expires after two years. Renewal is required before that date to remain in good standing. FINTRAC typically sends a reminder as your renewal date approaches. The renewal process involves reviewing your registration info, updating any sections as needed (and again providing fresh criminal record checks for owners/directors, since those must be updated biennially under the new rules), and submitting a renewal form. There is no government fee for renewal – it’s free (some sources incorrectly cite a $530 fee, but FINTRAC does not charge fees). The important part is timing: submit your renewal at least a few weeks (recommend 30 days) before expiration to avoid any lapse. If you miss the deadline, your MSB status could be set to “inactive” and you’d have to re-register from scratch, which could interrupt your business.

In addition to the above, continue to watch for new regulations. Canadian AML rules evolve – for example, in 2025 new obligations were introduced for certain businesses like crowdfunding platforms and white-label ATM operators to register as MSBs and implement full compliance regimes. FINTRAC often updates guidance, so stay informed (subscribe to FINTRAC’s email updates or industry newsletters).

Most critically, build a culture of compliance in your organization. That means management endorses compliance efforts, employees know compliance is a priority, and you allocate resources (time, technology, maybe external advisors) to keep your AML systems effective. By doing so, you not only meet your ongoing obligations but also gain the trust of banking partners and regulators, ensuring your MSB can operate without disruptions.

Bonus: MSB Registration Readiness Checklist

Before you submit that FINTRAC application, run through this checklist to make sure you haven’t missed any preparation steps. Being “registration-ready” means fewer surprises and delays.

✅ Canadian Business Entity is Set Up: You have incorporated or registered a company in Canada (with a Canadian address) and obtained the Certificate of Incorporation or equivalent. The company’s name and activities are aligned with MSB services.
✅ Business Number (BN): You have a federal Business Number from CRA (usually obtained at incorporation). (Not mandatory for FINTRAC, but essential for tax and banking purposes.)
✅ Ownership Chart & Directors List: You have a document (org chart or cap table) showing all owners and their ownership percentages, plus a list of all directors and senior officers. This clearly identifies anyone with ≥20% ownership.
✅ Criminal Record Checks for Principals: For each director, CEO, president, and 20%+ owner, you have a recent (last 6 months) police or background check certificate. Any required translations are done and certified.
✅ Compliance Officer Appointed: You have designated a Compliance Officer for the MSB (name, title, and contact info noted). This person is aware of their role and ideally has compliance experience or training.
✅ Written AML Compliance Program: You have a comprehensive AML/CFT compliance program document that includes policies/procedures for KYC, record-keeping, reporting, a risk assessment, and a training plan. It also outlines an independent two-year effectiveness review process. Even if FINTRAC doesn’t ask for the full document at registration, it’s ready and implemented.
✅ KYC Forms and Tools: You prepared the client onboarding forms or software (e.g., identity verification procedures, risk scoring model) you will use to identify clients and track transactions. This ensures you can describe your KYC process to FINTRAC if asked.
✅ Projected Transaction Volumes: You have estimates for the expected yearly transaction volume (in CAD) for each service (FX, transfers, crypto, etc.). These figures are defensible (not random) and based on your business plan.
✅ Bank Account or Financial Channel: Ideally, you have opened (or have an opening in progress for) at least one business bank account in your company’s name. If not, you have a plan for banking or payment processing and can explain it. Any available bank account details are ready to include.
✅ All Forms Completed Thoroughly: You have filled out the pre-registration form with extensive detail about your business model and are ready to complete the full form with all the information above. Double-check that business addresses, names, and dates are consistent across documents and forms.
✅ Response Plan for FINTRAC Questions: You are prepared to promptly answer any follow-up questions from FINTRAC. You’ve designated a primary contact (often the compliance officer or a consultant) to liaise with FINTRAC and monitor email/phone for communications so nothing is missed.

If you have all these boxes ticked, you stand a great chance of a smooth MSB registration process!

Partner with MapleBiz for Hassle-Free MSB Registration

Successfully registering and launching an MSB in Canada is a complex journey – but you don’t have to navigate it alone. MapleBiz is here to help fintech and crypto entrepreneurs achieve full MSB registration and compliance without the headaches. From incorporating your Canadian company to writing a rock-solid compliance program, MapleBiz’s experts handle all the heavy lifting. We’ll ensure your pre-registration form is complete and compelling (so you avoid the dreaded backlogs), prepare all required documents accurately, and interface with FINTRAC on your behalf to expedite approval.

With MapleBiz’s full-service MSB registration package, you get:

Professional Guidance at Every Step: Our team will walk you through each stage outlined in this guide, keeping you on schedule and in compliance. We’ve helped numerous startups obtain their FINTRAC MSB number successfully, even amid the new 2025 process changes.
Custom AML Compliance Program Setup: We don’t just register your business – we help you build the internal systems (KYC, reporting, training) you need to stay compliant after registration. MapleBiz provides tailored AML policies and training templates designed for your business model, ensuring you meet FINTRAC’s expectations from day one.
Avoidance of Common Pitfalls: By working with us, you won’t fall victim to the usual mistakes like missing documentation or unclear business descriptions. Our specialists double-check every detail and leverage their experience to present your application in the best light.
Peace of Mind and Time Savings: Instead of spending months wrestling with forms and regulations, you can focus on your product and customers. MapleBiz will manage the paperwork and follow-ups, reducing your registration timeline as much as possible.

Ready to get started? Don’t leave your MSB registration to chance – reach out to MapleBiz today for a consultation. We’ll assess your needs and take care of the rest, so you can launch your fintech or crypto venture with confidence and full legal compliance. Contact MapleBiz to kickstart your MSB registration and set your business on the path to success in Canada’s financial ecosystem.