CANADA MSB GUIDE
FINTRAC MSB Registration Documents Checklist
A FINTRAC registration file combines regulatory answers with evidence about the company and the people who own and manage it. Missing or inconsistent records can trigger clarification and delay.
The checklist below separates documents from business information. Both are required. A certificate of incorporation cannot explain the customer journey, and a business description cannot replace ownership evidence.
Use this list after the legal entity, directors, owners and proposed services have been confirmed.
Corporate existence and governance
Prepare the most recent records confirming the corporation's legal existence, name, address and directors. The records should reflect the structure in place when the registration package is submitted.
If a change is planned, decide whether it should be completed before submission. A share transfer or director change during preparation can make background checks and ownership records obsolete.
- Certificate or articles of incorporation
- Current registered address
- Current director and officer records
- Corporate resolutions where relevant
- Operating or business-name evidence
Ownership and control
Create a clear schedule showing direct and indirect ownership. Trace corporate shareholders through each layer to the ultimate owners and identify any person who exercises control without holding the same percentage of shares.
The ownership schedule should reconcile with share registers, shareholder agreements and group charts. Explain unusual control rights instead of leaving FINTRAC to infer them.
- Share register or securities ledger
- Ownership and control chart
- Ultimate beneficial-owner details
- Direct and indirect percentages
- Shareholder or control agreements where relevant
People, roles and criminal record checks
FINTRAC identifies the chief executive, president, directors and persons owning or controlling 20 per cent or more as people generally requiring criminal record checks. Equivalent roles can also be relevant regardless of title.
Checks must satisfy the issuing authority, recency and language requirements. Where a document is not in English or French, prepare the required translation and evidence of the translator's certification.
- Legal name, date of birth and address
- Role and ownership percentage
- Criminal record check issued no more than six months before submission
- English or French translation where required
- Translator certification statement or equivalent evidence
Business activities and expected volumes
Describe each MSB activity in operational terms. State who sends value, who receives it, which entity controls the transaction, which rails are used and how the service is completed.
Prepare a reasonable expected annual dollar value for each selected service. Keep the assumptions used to calculate the estimate so the amount can be explained and updated when the model changes.
- Foreign exchange activity
- Remittance or funds transmission
- Virtual-currency activity
- Payment or other covered activity where applicable
- Annual value estimate for each service
Locations, agents and operational contacts
List every place where the MSB business is carried on and every agent or mandatary operating on its behalf where applicable. A registered office, mailing address and genuine place of business can serve different functions and should not be treated as interchangeable without analysis.
Confirm the compliance officer and the person authorized to communicate with FINTRAC. Contact details must be monitored after registration so regulatory messages are not missed.
- Business and mailing addresses
- Branches and operating locations
- Agents and mandataries
- Compliance officer information
- Authorized FINTRAC contact
Final submission quality control
Run a line-by-line reconciliation before submission. The same legal name, owner, service, location and volume should not appear differently across the form, corporate records, diagrams and compliance program.
Create a final index, use readable scans and keep a complete archive of the submitted file. A strong record allows the team to answer clarifications and maintain the registration later without reconstructing the project from email.
- Document index and version date
- Readable scans and consistent file names
- Cross-document fact check
- Secure submission record
- Five-year retention planning for registration records
Turn the guidance into a project-specific route
Choose your company status and planned services to receive an immediate scope and fee estimate before sharing contact details.
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