The Canadian financial transactions regulator FINTRAC has significantly tightened requirements for companies engaged in money services. Some of the changes took effect on April 1, 2025, but the main package of innovations came into force on October 1, 2025. These changes are aimed at strengthening anti-money laundering and counter-terrorist financing efforts, but they also create an additional administrative burden for businesses.
The key change affects not only new registrations, but also the re-registration of existing companies. Foreign MSBs were already required to provide criminal record certificates for directors and owners every two years upon re-registration; now the same requirements apply to Canadian companies. This levels the playing field and closes loopholes that bad-faith market participants could exploit.
The registration process now requires more detailed disclosure of the corporate structure. Companies must provide not only basic incorporation documents, but also detailed information about ownership and control. For clients incorporated under the federal Canada Business Corporations Act and deemed high-risk, it is necessary to conduct a search in the Corporations Canada database.
This requirement creates an additional layer of verification: if the information provided by the company does not match the federal registry data, a discrepancy report must be filed within 30 days. Such a cross-check mechanism makes it much more difficult to conceal the real beneficial owners.
The document must have been issued no more than 6 months before the registration application is submitted. This means companies cannot use old certificates — they must plan to obtain the documents in advance, but not too early. The six-month period creates a narrow time window that requires precise planning.
MapleBiz helps clients build a document preparation schedule in such a way as to avoid situations where certificates expire before submission or are obtained too late, causing registration delays.
The twenty percent ownership threshold has become a critical cutoff point. Criminal record certificates are required from every person who owns or controls, directly or indirectly, 20% or more of the company’s shares. This applies to chief executive officers, presidents, directors, and all persons with equivalent authority, regardless of official titles.
Why 20% rather than 25%, as in some other jurisdictions? Industry associations proposed raising the threshold to 25% to align with beneficial ownership disclosure requirements, but the regulator rejected this proposal. A lower threshold broadens the scope of checks and makes it possible to identify more potentially influential persons in the company structure.
Direct ownership is easy to trace, but indirect control creates difficulties. Indirect ownership means control through a chain of intermediary structures — holding companies, trusts, partnerships. The company must independently identify all persons with such indirect control, which requires a deep analysis of the corporate structure.
MSBs that engaged agents before October 1, 2025 must complete the initial verification by October 1, 2027. This transitional provision gives a two-year adaptation period for existing agent relationships, but it does not remove the obligation.
For agents that are legal entities, the requirements are even stricter. For corporate agents, MSBs must obtain certificates for the chief executive officer, president, directors, and everyone who owns or controls at least 20% of the agent company. This creates a cascading effect of checks: not only does the MSB verify its own structure, but also the structure of all its agents.
Criminal record certificates must be obtained and verified within 30 days after the second anniversary of the agent’s last verification, if the agent continues to act on behalf of the MSB. Thus, a two-year renewal cycle is established for agents.
Canadian residents have access to two types of certificates: a basic name and date of birth check, or a certified fingerprint-based check through the RCMP. For MSB registration purposes, the latter is preferable, as it is considered more reliable.
Criminal record certificates must be issued by the competent authority of the country in which the person resides, or by an authority authorized to issue such documents in that country. For Canadian residents, the competent authority is the RCMP or the local police department, depending on the type of check.
It is important to plan certificate issuance in advance. Processing may take from several days to several weeks, depending on the type of check and the region. MapleBiz recommends starting the process at least three months before the planned registration submission date to allow time for possible delays.
When foreign beneficial owners are present in the MSB ownership structure, the complexity increases many times over. Each country has its own procedures for issuing criminal record certificates, processing times, and document formats. Some jurisdictions require in-person attendance, while others allow remote submission through accredited agencies.
It is critically important to ensure that the foreign certificate is issued by a competent authority. FINTRAC does not maintain an exhaustive list of recognized authorities for all countries, so responsibility for determining competence lies with the applicant. Usually this is the national police, the ministry of the interior or justice, or a specialized criminal records authority.
Since January 2024, Canada has joined the Hague Apostille Convention, which has simplified the legalization process for foreign documents. Now an apostille can be obtained for a Canadian criminal record certificate from Global Affairs Canada in Ottawa or through provincial authorities, depending on the place of issuance.
Documents in foreign languages require translation. If a document is in a language other than English or French, it must be translated into English or French and certified by a certified translator. FINTRAC requires confirmation of the translator’s competence — usually this is a certificate of authenticity with the translator’s signature, seal, or registration number.
MapleBiz specialists coordinate the entire process: from obtaining the certificate in the beneficial owner’s jurisdiction, through apostille legalization and certified translation, to submission to FINTRAC. This saves the client from having to navigate the intricacies of the requirements of different countries and authorities.
MSB registration is valid for two years from the date of initial approval, and a renewal application must be submitted before it expires. If the application is submitted on time, the registration remains active during processing. However, an overdue registration immediately receives the status "Expired" and requires re-registration as a new applicant — a much more labor-intensive process.
FINTRAC previously sent reminders 30 days before expiration, but this practice has ended. MSBs no longer receive notifications from FINTRAC about an approaching registration expiration and should not expect such a notice. Responsibility for tracking deadlines lies entirely with the company.
It is recommended to begin preparing for re-registration at least 90 days before expiration. This allows time to obtain fresh criminal record certificates (no older than 6 months), collect updated corporate documents, and conduct an internal review of changes in ownership and management structure.
The six-month age requirement creates a planning paradox. Obtain the certificate too early — and it may expire before submission. Obtain it too late — and you create registration delays. All information related to criminal record certificates must be obtained from the relevant authority within the last six months relative to the time of registration or re-registration.
This deadline is especially problematic for companies with foreign beneficial owners in jurisdictions with slow document processing. Some countries may take up to three months to process criminal record certificate requests, leaving only three months for apostille legalization, translation, and submission to FINTRAC.
There is also a risk that FINTRAC will request additional information (a clarification request), which prolongs the process. A clarification request is a method of communication with the MSB when FINTRAC needs additional information about the registration form, usually sent by email. If the certificates expire while such a request is being processed, new ones will need to be obtained.
Navigating FINTRAC’s updated requirements requires not only knowledge of the formal rules, but also an understanding of the practical nuances of their application. MapleBiz specializes in legal support for financial companies and has deep expertise in MSB registration and re-registration.
We help clients at every stage: from a preliminary audit of the corporate structure to identify all persons subject to certificate requirements, to coordinating the collection of documents from multiple jurisdictions. Our specialists monitor certificate validity periods, plan submission schedules, and interact with FINTRAC on the client’s behalf.
Our assistance is especially valuable for companies with international owners and agent networks. We coordinate the process of obtaining certificates, apostille legalization, and translation from various countries, ensuring that all documents comply with FINTRAC requirements. This saves the client from having to independently navigate the procedures of dozens of jurisdictions.
Non-compliance is now an offense under the PCMLTFA, punishable by a fine of up to $250,000 or imprisonment of up to two years on summary conviction, or a fine of up to $500,000 or imprisonment of up to five years on indictment. The cost of a mistake has become critically high, so professional support is not a luxury but a necessity for minimizing risk.
Contact MapleBiz for a consultation on registering or re-registering your MSB. We will help you complete this process without delays, penalties, or surprises, ensuring full compliance with all requirements of the Canadian regulator.
