FINTRAC MSB Registration — One Federal Registration, Quebec Licence Handled Separately

FINTRAC MSB registration runs through the online portal, with no government fee. FINTRAC states that the majority of complete applications are processed within three months of receipt; more complex files take longer. Incorporation (1–5 days) and account opening (2–6 weeks) come on top of that, so the full path to a working MSB is longer than the FINTRAC step alone. The package, and the back-and-forth with FINTRAC, we handle.

Yes. FINTRAC is a federal registration covering all ten provinces and three territories — no separate provincial MSB licence needed, unlike the US with its state-by-state licences. The exception is Quebec: Revenu Québec issues a separate provincial licence for MSBs under the Money-Services Businesses Act (Loi sur les entreprises de services monétaires). Provincial requirements, we assess at the outset.

To register you provide: the company legal name and CRA business number (BN), a description of the specific MSB activities (foreign exchange, transfers, virtual assets, etc.), names and addresses of all agents and branches, details on the compliance officer and beneficial owners (25% or more), and confirmation that a PCMLTFA program is in place. No registration fee. The registration is valid for two years and is renewed before it expires.

Yes — a non-resident can own a Canadian corporation registered as an MSB. The company needs a Canadian registered address and a compliance officer accessible to FINTRAC, with all PCMLTFA records held in Canada or accessible from Canada. The address, a Canadian compliance officer, and the record-keeping infrastructure come from us.

Under the PCMLTFA, MSB registration is mandatory for commercial dealing in any of: (1) foreign exchange dealing; (2) money transfers / remittance; (3) issuing or redeeming money orders, traveller's cheques, and similar instruments; (4) virtual currency exchange or transfer. Incidental exchange within another business (a hotel, say) generally doesn't trigger it. The test is commercial dealing, not volume. On activity classification, we advise before you file.