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CANADIAN MSB GUIDE

What You Need to Prepare for a Canadian MSB

Canadian MSB preparation involves more than completing a registration form. FINTRAC needs to understand the legal entity, the people behind it, the services it will provide and the controls it will use to meet ongoing obligations.

The checklist below organizes the work into decisions, information and documents. It can help a founder spot missing pieces before the pre-registration stage starts.

Treat the checklist as a coordination tool, not a collection exercise. A fact such as a new owner or agent can affect several documents and controls at once. Recording those relationships helps the final package remain consistent and gives the operating team a usable compliance record.

A suitable Canadian company and clear operating role

Start with the entity that will actually provide the covered services. Its legal name, business names, registered office and place of business should be settled. Corporate records should identify the current directors, officers and shareholders without relying on an outdated cap table.

If a group has several entities, document which one contracts with customers, receives fees, controls the platform and holds or directs funds. Multiple corporate layers are not automatically prohibited, but they require a clear ownership trail and a credible commercial reason.

  • Certificate and articles of incorporation
  • Registered office and Canadian place of business
  • Current registers of directors, officers and shareholders
  • Shareholder or control structure
  • Business names used with customers

Ownership, management and control information

FINTRAC registration asks who owns and manages the entity. Prepare legal names, dates of birth, addresses, positions and ownership percentages for the relevant people. Indirect ownership should be traced through each corporate layer to the individuals who ultimately own or control the applicant.

Changes during the project need to be recorded. Adding a director, transferring shares or inserting a holding company can affect corporate documents, criminal record checks, the registration form and the risk assessment at the same time.

  • Chief executive or president
  • Directors and senior officers
  • Direct and indirect shareholders
  • People owning or controlling 20 per cent or more
  • Authorized registration contact

Compliance officer and governance

Every MSB needs a person responsible for implementing the compliance program. The officer should have enough authority, access and knowledge to oversee policies, risk assessment, training, reporting and the effectiveness review.

A title alone is not enough. Record the officer’s responsibilities, escalation route, access to management and resources. If operational tasks are delegated to vendors or employees, the officer remains responsible for oversight and should understand what evidence will be retained.

  • Formal appointment or board approval
  • Written role description
  • Access to customer and transaction information
  • Escalation and reporting line
  • Backup and continuity arrangements

Services, volumes, locations and agents

Describe each covered service in operational terms. For example, state who sends value, who receives it, which rails are used, when the MSB controls it and how the transaction is completed. Marketing labels such as fintech platform or payment solution are too broad by themselves.

Prepare reasonable annual transaction-value estimates for each service and list every business location, branch, agent, mandatary or representative. Estimates can change, but they should have a documented basis that can be explained.

  • Customer types and countries
  • Delivery channels and onboarding method
  • Fiat and virtual-currency flows
  • Expected transaction counts and values
  • Canadian and foreign locations
  • Agents, mandataries and service providers

Criminal record checks and corporate documents

FINTRAC specifies criminal record checks for the chief executive or president, directors and people who own or control 20 per cent or more. Checks generally must be issued no more than six months before submission. A document that is not in English or French needs a translation that meets the stated requirements.

Coordinate the checks with the final ownership and board structure. Ordering them before the relevant people are confirmed can waste time and money. Governance documents should also be current, internally consistent and signed where required.

  • Confirm every person in scope
  • Check issuing-country and document requirements
  • Monitor the six-month validity window
  • Arrange translations where needed
  • Keep clear copies and submission records

The AML/ATF compliance program

An MSB must establish a compliance program with five required elements: a compliance officer, written policies and procedures, a documented risk assessment, an ongoing training program and plan, and a review of effectiveness at least every two years.

The program should reflect the services, customers, geography, channels, technology and transaction patterns of the planned operation. It also needs practical procedures for client identification, beneficial ownership, records, reporting, sanctions-related escalation where relevant and updating controls when risks change.

  • Compliance officer appointment
  • Policies and procedures approved by a senior officer
  • Business and relationship risk assessment
  • Training content, audience and schedule
  • Independent effectiveness-review framework

A final readiness check

Before submission, compare the corporate records, registration answers, flow diagrams and compliance documents side by side. Names, services, ownership, locations and expected volumes should match. Resolve open questions rather than hiding them in vague wording.

Also decide who will maintain the records after registration. A good setup leaves the operating team with owners and next actions, not just documents. Registration details, policies and training should be reviewed whenever the business adds a material service, market, channel or ownership change.

  • Confirm a single agreed business description
  • Reconcile owners and directors across documents
  • Test that reporting and recordkeeping responsibilities are assigned
  • List remaining external dependencies
  • Set dates for training, review and registration maintenance

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