CANADA MSB GUIDE
FINTRAC Clarification Requests: What an MSB Must Do
A FINTRAC clarification request is a regulatory deadline, not a routine email. It usually means the officer needs missing, corrected or better-supported information before the file can move forward.
FINTRAC's current guidance gives 30 days to respond. A missed or incomplete response can delay the application and may contribute to denial or revocation.
The response should answer each question directly and reconcile every document affected by a changed fact.
Secure the deadline and the complete request
Record the date received, response deadline, case reference and every requested item. Assign one response owner and a backup immediately.
Keep monitoring the registered contact inbox and any former contact channel until a recent update is confirmed. A request cannot be managed if it remains in one person's unread mailbox.
- 30-day response window
- Primary owner and backup
- Case and document index
- Monitored regulatory inbox
- Internal approval date
Answer in the same order
Use the officer's numbering and give one clear response to each question. Identify the supporting attachment and explain where the relevant evidence can be found.
Avoid sending a pile of replacement documents without an explanation. The reviewer should be able to see what changed, why it changed and which previous statement is being corrected.
- Question-by-question response
- Direct factual answer
- Named supporting evidence
- Clear change explanation
- Version-controlled attachments
Reconcile the connected documents
A new owner, service, address or transaction role can affect the corporate records, registration form, flow diagram, risk assessment and operating procedures at the same time.
Review the full factual chain before submitting the response. Correcting only one document can create a new inconsistency and another clarification cycle.
- Corporate and ownership records
- Service and funds-flow description
- Locations and agents
- Compliance programme
- Volumes and launch plan
Use specialist support when the issue is material
A clarification about eligibility, place of business, ownership or a significant change may require more than drafting. It may require a route review, corrective corporate action or Canadian legal advice.
MSB Desk can coordinate the response package and, where a formal legal review is needed, coordinate with Canadian counsel rather than presenting ordinary project support as legal representation.
- Urgent scope review
- Corrective-document plan
- Evidence preparation
- Response coordination
- Canadian counsel coordination where needed
Turn the guidance into a project-specific route
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