FINTRAC Reporting Requirements for MSBs in Canada

A money services business in Canada must register with FINTRAC before it operates, run a compliance program that works in practice, identify clients when required, keep prescribed records, and file its transaction and property reports on time.

Five reports carry most of the load: suspicious transaction reports, large cash transaction reports, electronic funds transfer reports, large virtual currency transaction reports and listed person or entity property reports. Most threshold reports start at $10,000. A suspicious transaction report has no dollar threshold at all.

The biggest change for 2026 is a legal standard. Since March 26, 2026, a compliance program has to be reasonably designed, risk-based and effective. A written manual is no longer the finish line; you need to be able to show that the procedures work in daily operations.

An accountant's view. The strongest MSB files connect the transaction record, the client information, the source documents, the risk decision and the report that was filed. Your records should show what happened, who reviewed it, why the decision was made, and whether the required report went in on time.

What is a money services business in Canada?

A business is generally an MSB for FINTRAC purposes when it has a place of business in Canada and offers at least one regulated money service. A foreign business that directs those services at clients in Canada can fall under the foreign MSB rules instead.

The regulated services include foreign exchange dealing, remitting or transmitting funds, issuing or redeeming money orders and similar negotiable instruments, dealing in virtual currency, crowdfunding platform services, transporting currency or certain negotiable instruments, cheque cashing, and some acquirer services for private automated banking machines.

Registration is federal, and a provincial licence does not replace it. An MSB must register before it starts operating in Canada, even if a province or territory has already licensed it. FINTRAC does not charge a registration fee. For founders entering Canada from abroad, the registration question usually sits alongside how the business is owned and structured in Canada, and it is worth settling both before the application goes in.

What changed in 2025 and 2026

The rules around MSBs have moved a long way since the start of 2025. That matters because a manual written before these changes can miss registration, agent and program effectiveness requirements that now apply.

• April 1, 2025 - cheque cashing businesses came into the federal reporting framework.
• October 1, 2025 - stronger eligibility rules took effect, including criminal record checks, and MSBs became responsible for verifying the eligibility of their agents and mandataries.
• March 26, 2026 - the Strengthening Canada's Immigration System and Borders Act amended the Proceeds of Crime (Money Laundering) and Terrorist Financing Act so that compliance programs must be reasonably designed, risk-based and effective.
• March 26, 2026 - the same Act rebuilt the administrative monetary penalty framework. Maximum penalties rose to as much as 40 times their previous limits, and prescribed violations now bring mandatory compliance agreements and possible compliance orders.
• July 15, 2026 - FINTRAC refreshed its advisory on countries identified by the Financial Action Task Force. Geographic risk controls and ministerial directive procedures should reflect the current version, not last year's.

The five main FINTRAC reports

1. Suspicious Transaction Report

You file a Suspicious Transaction Report when a completed or attempted transaction gives you reasonable grounds to suspect it is connected to money laundering, terrorist activity financing or sanctions evasion.

There is no minimum amount. A $200 transaction can be reportable if the facts, the context and the indicators support reasonable grounds to suspect. Once you have completed the measures that take you to that threshold, the report goes to FINTRAC as soon as practicable, and FINTRAC expects it to be treated as a priority. The client must not be told about it.

Your procedures should say how staff escalate unusual activity, who makes the final reporting decision, how the facts and context are documented, and how the deadline is tracked.

2. Large Cash Transaction Report

A large cash transaction is one where you receive $10,000 or more in cash in a single transaction. The report is due within 15 calendar days after the day you receive the cash.

The 24-hour rule can also trigger it: two or more cash amounts totalling $10,000 or more within a consecutive 24-hour window, where they share the same conductor, the same third party or the same beneficiary.

3. Electronic Funds Transfer Report

MSBs report qualifying international electronic funds transfers of $10,000 or more. In general you report when you initiate a qualifying international transfer or finally receive one, subject to FINTRAC's detailed rules on role and location.

The report is due within 5 business days after the day the transfer is initiated or finally received, and the 24-hour rule applies here too.

4. Large Virtual Currency Transaction Report

You file a Large Virtual Currency Transaction Report when you receive virtual currency worth the equivalent of $10,000 or more in a single transaction, or in two or more transactions that total that amount within a consecutive 24-hour window. It is due within 5 working days after the day you receive it.

For the accounting side this raises a control of its own. The Canadian dollar value has to come from an exchange-rate method you apply consistently in the normal course of business, and your records should let a reviewer reproduce how each amount was reached.

5. Listed Person or Entity Property Report

When you are required to make a disclosure about property under the terrorist property or sanctions legislation FINTRAC's guidance covers, you submit a Listed Person or Entity Property Report immediately. This is not a threshold report.

It replaced the Terrorist Property Report in 2025, when the reporting obligations were expanded to cover listed persons and entities under sanctions law. Screening procedures, escalation contacts and internal forms should all use the current name and the wider scope.

A 2026 geographic risk point. Under the ministerial directive on Iran, reporting entities must treat every transaction originating from or bound for Iran as high risk regardless of its amount, keep a record of it, and report all such transactions to FINTRAC. The July 15, 2026 advisory restates this. A country risk list is not a checklist you update once a year.

How the 24-hour rule changes threshold reporting

One of the most common operational mistakes is checking only the size of each individual transaction. FINTRAC requires aggregation for large cash, large virtual currency and qualifying electronic funds transfers: when several transactions of the same type total $10,000 or more within a consecutive 24-hour window and share the required connection, they are reported together.

FINTRAC also expects the process to run across the whole business. If you have several branches, channels or systems, the control cannot stop at one counter, one location or one member of staff.

• Define the start and end of your 24-hour window in your procedures.
• Aggregate across every relevant location and system.
• Record conductor, third-party and beneficiary information accurately, because that is what connects the transactions.
• Never let the $10,000 threshold stand in for suspicious transaction monitoring.

What an MSB compliance program must contain in 2026

The compliance program is the operating system behind every other obligation. FINTRAC describes five elements, and the March 2026 amendment adds a quality standard across all of them: the program must be reasonably designed, risk-based and effective.

• Compliance officer - a person with the authority and access to resources to implement and oversee the program.
• Policies and procedures - written, kept up to date and, for an entity, approved by a senior officer. They should cover registration, client identification, reporting, record keeping, monitoring and every other obligation that applies.
• Risk assessment - of your clients, products, services, delivery channels, geography and new technology, with stronger controls where the risk is higher.
• Training - so staff understand the rules for their role and know how to escalate.
• Effectiveness review - a documented test of whether the program works, carried out at least every two years, with the results reported in writing to a senior officer within 30 days of finishing it.

A good program is measurable. You should be able to produce exception reports, escalation logs, training records, filing confirmations, risk decisions and remediation records. That evidence is what a FINTRAC examination looks for.

Setting this up alongside your books is much of what our FINTRAC MSB registration service does: the compliance officer role, the policies, the risk assessment, training and review planning, built around how your business actually operates.

Registration and renewal

FINTRAC registration is not a one-time filing. It is valid for two years, and you must renew before the expiry date. FINTRAC is explicit that renewing on time is the business's responsibility. It says the majority of complete applications are processed within three months, while more complex ones can take longer, so renewal preparation belongs in your compliance calendar well ahead of the date.

The registration also has to be kept current:

• changes such as a new address for your contact person or your representative for service in Canada must be reported within 30 days;
• a foreign MSB that fails to report a change to its Canadian representative within 30 days can have its registration revoked or denied;
• if the business stops qualifying as an MSB or stops offering MSB services, it must cease its registration within 30 days, and failing to do so can bring penalties or criminal charges;
• clarification requests from FINTRAC must be answered within 30 days.

Criminal record and agent checks

Registration now requires criminal record checks for the chief executive officer, the president, the directors, and each person who owns or controls 20% or more of the entity or its shares. A sole proprietor provides one for themselves. Each check must come from a competent authority in the country where the person lives and be issued no more than six months before the application is submitted.

For agents and mandataries, the eligibility verification and criminal record review requirements came into force on October 1, 2025. An MSB that had already engaged an agent before that date has until October 1, 2027 to complete them. New agents should already be going through these checks at onboarding.

Know your client, beneficial ownership and record keeping

Reporting is only one part of FINTRAC compliance. Depending on the transaction and the relationship, MSBs also carry client identification, business relationship, ongoing monitoring, beneficial ownership, third-party determination, politically exposed person, record keeping and travel rule obligations.

From an accounting and systems point of view, the practical goal is to avoid fragmented evidence. The transaction ledger, client profile, identification record, third-party details, beneficiary data, source information, risk rating and report reference should be connected, so that one transaction can be followed from start to finish.

Procedures also have to be usable by the people who follow them. A reviewer should be able to trace a transaction without rebuilding the file from scattered emails and spreadsheets, and a new member of staff should be able to follow the escalation steps without asking.

Money services business regulations, and the Act that isn't

When people search for money services business regulations in Canada, they usually mean the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act, its regulations and FINTRAC's guidance. Canada has no federal statute called the Money Services Business Act.

Quebec is the exception. It has its own Money-Services Businesses Act, administered by Revenu Québec, and a business offering regulated money services in Quebec can need a provincial licence as well as federal FINTRAC registration. Map your obligations by both level of government and by province: FINTRAC registration alone does not prove that every provincial requirement is met.

What FINTRAC enforcement looks like in 2026

Enforcement is active and increasingly focused on risk. In its 2024 to 2025 annual report, FINTRAC says it carried out 294 formal examinations, and that money services businesses were one of the top three sectors examined. It issued 23 notices of violation totalling more than $25 million, the largest number in a single year in its history.

The same report counts 2,778 registered MSBs as of March 31, 2025, after 509 new registrations and 351 renewals during the year.

Enforcement has continued into 2026. On May 14, 2026, FINTRAC announced a penalty of $693,742.50 against an Edmonton money services business, imposed on March 27, 2026, for five violations found during a compliance examination:

• failing to submit suspicious transaction reports on several occasions where there were reasonable grounds to suspect;
• failing to develop and apply written compliance policies and procedures that were kept up to date and approved by a senior officer;
• failing to apply adequate enhanced measures to high-risk transactions and clients;
• failing to assess and document money laundering and terrorist financing risk using the prescribed factors;
• failing to keep sufficient occupation and transaction information for virtual currency exchange records.

What this tells an operator

FINTRAC does not only check whether a manual exists. Reporting quality, risk decisions, enhanced measures, records and day-to-day execution can all become examination findings, and for violations after March 26, 2026, the penalty ceiling is far higher than it was.

A 12-point MSB compliance checklist

1. Confirm every regulated money service you provide and every jurisdiction you operate in.
2. Confirm your FINTRAC registration is active before providing MSB services.
3. Put your registration expiry date, and a renewal preparation date well ahead of it, into a controlled compliance calendar.
4. Report changes to your registration details within 30 days.
5. Make sure agent and mandatary eligibility and criminal record checks meet the rules in force since October 2025.
6. Update your risk assessment for the March 2026 effectiveness standard and the latest geographic risk information.
7. Test how your systems catch single transactions of $10,000 or more and the 24-hour aggregation.
8. Confirm suspicious transaction escalation has no minimum dollar filter.
9. Test your filing deadlines for cash, virtual currency, international electronic funds transfers and listed property reports.
10. Link transaction records to client, third-party, beneficiary and source information.
11. Keep training, review, remediation and filing evidence so the controls can be demonstrated.
12. Review the July 2026 FINTRAC country advisory and your ministerial directive procedures.

Frequently asked questions

What are FINTRAC's reporting requirements for an MSB in Canada?

An MSB must register before operating, maintain a compliance program, identify clients when required, keep records and submit the required reports. The main reports are the suspicious transaction, large cash transaction, electronic funds transfer, large virtual currency transaction and listed person or entity property reports.

Which transactions have to be reported?

Suspicious completed or attempted transactions, cash receipts of $10,000 or more, qualifying international electronic funds transfers of $10,000 or more, virtual currency receipts worth $10,000 or more, and required disclosures about listed person or entity property. The 24-hour rule can combine smaller transactions into a reportable total.

Is $10,000 the only trigger?

No. Several reports use a $10,000 threshold, but a suspicious transaction report has no minimum amount. A small transaction still has to be reported once there are reasonable grounds to suspect.

How quickly does each report have to be filed?

Suspicious transaction reports as soon as practicable, large cash transaction reports within 15 calendar days, electronic funds transfer reports within 5 business days, large virtual currency transaction reports within 5 working days, and listed person or entity property reports immediately.

What does FINTRAC compliance require from an MSB in 2026?

More than filing reports. An MSB needs registration, client identification, record keeping, ongoing monitoring, beneficial ownership and third-party checks where they apply, and a compliance program that is reasonably designed, risk-based and effective.

How does an MSB prove compliance during an examination?

By producing current procedures, risk assessments, training records, monitoring evidence, report confirmations, client and transaction records, and remediation evidence. The records need to show the controls operating in practice, not only on paper.

What must an MSB compliance program include?

A compliance officer, written policies and procedures, a risk assessment, a training program and an effectiveness review. Since March 26, 2026, the program must also be reasonably designed, risk-based and effective.

How often should the compliance program be reviewed?

The effectiveness review must happen at least every two years, testing the policies and procedures, the risk assessment and the training program. It should also be updated sooner when the business, its risks, the rules or its systems change materially.

How long does FINTRAC registration last?

Two years. You must renew before the expiry date, report changes to your registration within 30 days, and cease the registration within 30 days if the business stops offering money services.

Is there a federal Money Services Business Act?

No. Federal MSB obligations come from the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations. Quebec has its own Money-Services Businesses Act, so an MSB operating there can need a Revenu Québec licence as well as FINTRAC registration.

Get your MSB compliance on a firm footing

FINTRAC's expectations have moved from "do you have a manual" to "can you prove it works", and the penalties for violations after March 2026 reflect that. If you are registering an MSB, renewing one, or rebuilding a program written before these changes, our FINTRAC MSB registration and compliance team can help, or you can talk to us directly. We are available Monday to Saturday, 9am to 8pm.