Money Services Business Licence - Canada
Two federal registers, two different purposes: FINTRAC for anti-money laundering, the Bank of Canada for retail payment activities.
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The short answer
Canada has two distinct federal registration regimes for money movement businesses, and most firms need to consider both. FINTRAC registers money services businesses and foreign money services businesses under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Registration is free, must be in place before services are provided, and is renewed every two years. It is an anti-money laundering registration, not a prudential licence.
The Bank of Canada supervises payment service providers under the Retail Payment Activities Act. That regime is about operational risk, incident response and safeguarding of end-user funds, and it applies to firms performing retail payment functions in relation to electronic funds transfers in Canadian dollars or other currencies, including foreign payment service providers directing services at Canada.
A firm that transfers funds for Canadian customers frequently sits inside both regimes at once. Registering with one does not satisfy the other, and the two registers ask different questions.
Key facts
FINTRAC: which activities are captured
The test is whether the services are offered to the public. A foreign money services business is captured where it has no Canadian place of business but directs those services at persons or entities in Canada and has Canadian customers. Marketing into Canada, Canadian dollar pricing and Canadian-facing onboarding all point towards the obligation.
- •Foreign exchange dealing
- •Money transferring by any means
- •Issuing or redeeming money orders, traveller's cheques or similar negotiable instruments
- •Dealing in virtual currency, including exchange and transfer services
- •Crowdfunding platform services
The five-pillar compliance programme
FINTRAC examines the programme, not the registration form. Deficiencies in these five pillars drive most administrative monetary penalties, and a programme drafted after registration rather than before operations begin is the most common structural failure.
- •A compliance officer with authority and resources to implement the programme
- •Written policies and procedures approved by a senior officer and kept current
- •A documented risk assessment covering clients, products, delivery channels, geography and new technologies
- •Ongoing training for employees, agents and mandataries
- •An effectiveness review at least every two years covering the policies, the risk assessment and the training
When the RPAA also applies
The Retail Payment Activities Act captures firms that perform a retail payment function: provision or maintenance of an account, holding funds, initiation of an electronic funds transfer, authorisation or transmission of a transfer instruction, and the provision of clearing or settlement services. A foreign provider is captured where it performs retail payment activities for an end user in Canada and directs those activities at persons in Canada.
The obligations are operational rather than anti-money laundering: a risk management and incident response framework, incident notification, safeguarding of end-user funds where the provider holds them, and annual reporting to the Bank of Canada. Because FINTRAC registration and RPAA registration test different things, a firm can be fully compliant with one and unregistered under the other.
Virtual currency businesses
Dealing in virtual currency is a listed money services business activity, so exchanges and transfer providers serving Canadian customers register with FINTRAC as an MSB or foreign MSB. Additional reporting applies, including large virtual currency transaction reports and travel rule information on transfers.
Securities regulation sits separately with the provincial securities administrators. FINTRAC registration does not resolve provincial securities obligations for platforms trading crypto contracts, and treating it as though it does is a recurring error in Canadian market entry plans.
Ongoing Canadian compliance
- •Suspicious transaction reports, large cash and large virtual currency transaction reports, and prescribed electronic funds transfer reports
- •Client identification, beneficial ownership and business relationship records retained for the prescribed periods
- •Updates to registered information, including agents, branches, ownership and the compliance officer, within the prescribed period
- •Two-year FINTRAC renewal, started well before expiry
- •Where the RPAA applies, annual reporting, incident notification and continuous maintenance of the risk management framework
Definitive guides for this market
Canada MSB registration (FINTRAC)
Definitive guide: captured activities, MSB versus foreign MSB, programme, reporting and renewal.
Canada RPAA registration (Bank of Canada)
Payment service provider registration: payment functions, safeguarding, incidents and reporting.
US FinCEN MSB registration
The federal US equivalent, frequently paired with Canadian registration.
AML and financial crime advisory
Programme design, risk assessment and effectiveness review.
Primary sources
- FINTRAC: money services businesses
- Proceeds of Crime (Money Laundering) and Terrorist Financing Act
- Bank of Canada: retail payments supervision
- Retail Payment Activities Act
Last reviewed by the Regulatory Counsel team on 28 August 2026.
Frequently Asked Questions
No. The foreign money services business category exists precisely for providers with no Canadian place of business that direct services at Canadian customers. Many firms still incorporate in Canada, but for banking access rather than because FINTRAC requires it.
FINTRAC does not charge a registration fee. The real cost of the project is the compliance programme, the compliance officer function and the reporting infrastructure that must be in place before services begin.
Frequently yes. FINTRAC registration addresses anti-money laundering obligations under the PCMLTFA. Bank of Canada registration under the Retail Payment Activities Act addresses operational risk and safeguarding for retail payment activities. They are separate registers with separate tests.
FINTRAC requires registration before services are provided, and has indicated that most complete renewal applications are processed in about three months. The controlling factor for a new entrant is preparation of the compliance programme rather than the form itself. Where the RPAA applies, plan the Bank of Canada submission in parallel rather than sequentially.
No. Quebec operates its own money services business licensing regime through the Autorité des marchés financiers, and other provincial requirements can apply. Federal registration is the baseline, not the whole picture.