How to Get a Money Service Business (MSB) License in Canada: A Step-by-Step Guide
Canada is a major player in global finance and fintech, offering a regulated yet accessible environment for businesses involved in currency exchange, remittances, trading, and financial transfers. But to operate legally in this space, you’ll need to enroll as a Money Services Business (MSB).
Whether you’re launching a fintech startup, platform, remittance company, or desk, this article walks you through how to get an MSB license in Canada—step by step.
We cover who needs a license, how to apply, what documents you need, how to stay compliant, and how long it takes. Let’s get started.
1. What Is an MSB in Canada?
An MSB (Money Services Business) is any business that offers one or more of the following favors to the public:
- Foreign exchange dealing
- Money transferring (including remittances)
- Issuing or redeeming money orders, traveler’s cheques, or similar
- Dealing in virtual currencies (ATMs, wallet services)
- Crowdfunding platforms (if handling funds on behalf of others)
- These businesses are regulated federally by FINTRAC—the Financial Transactions and Reports Analysis Centre of Canada.
Note: If you’re operating without MSB registration, you’re breaking the law—even if you’re only working online or with small volumes.
2. Who Needs to Register?
You must register as an MSB if:
- You are based in Canada and provide MSB services
- You are based outside country but offer MSB favors to Canadian customers (you will be deemed a foreign MSB)
- You act as an agent for another MSB or provide services under your own brand
Examples of businesses that must register:
- P2P payment apps
- Money remittance companies
- Currency exchange kiosks
- Digital wallets
- White-label banking providers
- ATM operators offering
- If you’re unsure, it’s safer to assume you need registration—and speak with a compliance professional or FINTRAC directly.
3. Regulatory Bodies You Need to Know
a) FINTRAC (Financial Transactions and Reports Analysis Centre of Canada)
Main body for MSB registration and compliance
Focuses on AML (Anti-Money Laundering) and counter-terrorist financing (CTF)
b) CRAanada Revenue Agency)
May be involved for tax purposes if you offer financial services
c) Provincial Regulators
Some provinces like Quebec may require additional licensing (e.g. from AMF – Autorité des marchés financiers)
Tip: Federal registration with FINTRAC is mandatory for all. Provincial licensing may apply in addition, not instead.
4. Step-by-Step Guide to Getting an MSB License in Canada
Let’s break down the process from start to finish.
Step 1: Incorporate Your Business
Before applying for a license, your firm must be legally registered in Canada or overseas (if applying as a foreign MSB).
- Register a federal or provincial corporation
- Ensure the company name is unique and acceptable
- Appoint directors and shareholders
- Get a business number (BN) from CRA
Note: Foreign MSBs must still form a legal entity in their home country and disclose owners and controllers to FINTRAC.
Step 2: Create a Compliance Program
This is the most important part of the application—and where many businesses get stuck.
- You must develop a full AML/CTF compliance program, including:
- A written compliance policy
- A risk assessment framework
- Appointment of a Compliance Officer
- Know Your Customer (KYC) procedures
- Record-keeping policies
- Transaction monitoring and suspicious activity reporting process
- Ongoing training program for staff
- Your compliance manual must reflect FINTRAC’s guidelines and be customized to your business model—not copied from a template.
- Tip: Work with a compliance consultant if you’re unsure. A weak compliance plan will result in delays or rejection.
Step 3: Create an MSB registration profile
Fill out:
- Business information (name, address, type)
- Services offered
- Compliance officer details
- Ownership structure
- Upload or input your compliance documents
- There is no governance fee for MSB enrollment with FINTRAC.
Step 4: Wait for Review and Respond
FINTRAC may:
- Approve the registration quickly (1–4 weeks)
- Ask for additional documentation or clarification
- Require changes to your compliance program
- Stay responsive. Incomplete or unclear answers can delay the procedure significantly.
- Note: Approval does not mean FINTRAC endorses your business—only that you are registered and accountable.
Step 5: Set Up Operational Controls
Once registered, you’ll need to ensure your operations are compliance-ready.
This includes:
- Secure record-keeping system (for 5 years minimum)
- Employee AML training
- KYC software or manual processes
- Policies for handling suspicious transactions
- Monthly, quarterly, or ad-hoc reporting to FINTRAC
- Your business must be “audit-ready” at any time.
5. What’s Required for Virtual Asset MSBs?
If you’re offering services involving virtual currencies, you must meet additional conditions:
MSBs must:
- Identify and verify customers using (even unhosted wallets)
- Report large virtual currency transactions (CAD 10,000+)
- Keep detailed logs of wallet addresses, transfer hashes, and KYC records
- Notify FINTRAC of suspicious activities
- MSBs are treated equally seriously as fiat MSBs—perhaps more, given risk perception.
6. How Long Does It Take?
Typical timeline:
- Business incorporation: 1–2 weeks
- Compliance program creation: 2–4 weeks
- FINTRAC review: 1–6 weeks
- Total time: Around 4–10 weeks, depending on readiness and complexity
- Tip: Speed depends on how well-prepared your documents and responses are.
7. Common Mistakes to Avoid
Many MSB applications are delayed or denied for avoidable reasons. Watch out for:
- Generic or copied compliance manuals
- Not appointing a real Compliance Officer
- Not knowing your risk exposure (e.g. customer geography)
- Weak KYC or source of funds policies
- Failing to train staff or document procedures
- Ignoring virtual currency-specific obligations
- Pro tip: Even after approval, FINTRAC can fine or suspend you for non-compliance. Treat compliance as an ongoing process, not a one-time box check.
8. What Happens After You’re Licensed?
Registration is just the beginning. You must:
- File biennial MSB renewals
- Update FINTRAC of any changes (ownership, services, address)
- Report suspicious transactions
- File Large Cash Transaction Reports (10,000+ CAD)
- Keep training logs, client files, and transaction records
- Prepare for random FINTRAC audits or inspections
- Failure to comply can result in:
- Administrative fines (up to $100,000+ per violation)
- Revocation of MSB registration
- Criminal prosecution in serious cases
9. Do You Need a Separate Bank Account?
Yes. You’ll need a dedicated business account for your MSB.
- But here’s the hard part: many Canadian banks are cautious about MSBs—especially related ones.
Your options:
- Apply to major banks (RBC, TD, Scotiabank), but expect extra screening
- Use credit unions or digital banks more open to fintech
- Prepare strong compliance documentation to win trust
- Explore international banking options if local banks decline
- Note: Having an MSB license doesn’t guarantee bank access—you still need to meet the bank’s risk profile.
10. Foreign MSBs: Serving Canadian Clients from Abroad
- If you’re not based in Canada but offer favors to Canadian residents, you must enroll as a Foreign MSB.
- Demands are similar:
- Enroll online with FINTRAC
- Provide a Canadian compliance contact
- File reports on Canadian clients and transactions
- Maintain full AML program
- Be audit-ready—even from abroad
Tip: Many and fintech firms based in Europe, Asia, or the U.S. are now registering as foreign MSBs to legally serve Canadian users.
11. Can You Sell or Transfer an MSB License?
No — an MSB-license in Canada cannot be sold or transferred from one business to another. The enrollment is tied to the specific legal entity (including its ownership, structure, and activities) that applied for it.
If you sell your company:
- The new owners must notify FINTRAC of the change
- A material change in ownership or business model may trigger a new compliance review
- In some cases, FINTRAC may require the company to re-register
- If you’re acquiring an MSB:
- Conduct thorough regulatory due diligence
- Review all past compliance filings and any audit reports
- Confirm the entity is in good standing with FINTRAC and has no outstanding issues
- Pro tip: Always consult a Canadian regulatory lawyer when dealing with MSB M&A transactions. Assumptions about transferability can delay or derail deals.
Final Thoughts
Canada offers a clear, regulated, and globally respected framework for money services businesses—but only if you follow the rules.