FINTRAC Money Services Business Registration Regime for Virtual Currency Dealers

The regime covers businesses that deal in virtual currency through exchange or transfer services. FINTRAC describes exchange services as transactions involving funds for virtual currency, virtual currency for funds, or one virtual currency for another. Transfer services include sending virtual currency at a client’s request or receiving a virtual-currency transfer for remittance to a beneficiary. The regulatory definition generally focuses on a digital representation of value, or a private key enabling access to it, that can be used for payment or investment and readily exchanged for funds or another readily exchangeable virtual currency.

Both domestic and foreign providers can fall within scope. A domestic money services business may have a Canadian place of business because it is incorporated in Canada, has a physical location there, or has employees, agents or branches there. A foreign money services business is generally a provider without a Canadian place of business that directs covered services at persons or entities in Canada and actually serves clients in Canada. The statutory framework therefore reaches qualifying offshore platforms as well as Canadian businesses.

A covered money services business or foreign money services business must register with FINTRAC before beginning operations in Canada. Registration is free, but it remains necessary even where a business is separately registered or licensed by a province or territory. The application requests information about the compliance officer, ownership and senior management, expected transaction volumes, locations, agents or mandataries, and corporate formation. Foreign applicants must also designate a Canadian resident authorized to accept FINTRAC notices.

Current applications require recent criminal-record checks for an individual applicant or, for an entity, its chief executive officer, president, directors, and each person who owns or controls at least 20%. Applicants must also provide documents confirming the entity’s existence, ownership, control and structure. Registrants must notify FINTRAC of material application-information changes within 30 days, generally renew every two years, and notify the agency within 30 days after ceasing a registered activity. FINTRAC’s public registry is a record of legal registration; FINTRAC states that listing is not an endorsement, licence or certificate.

Registration is only one part of the federal framework. Covered businesses must maintain a compliance program, verify identity for prescribed activities, perform applicable customer due diligence, keep required records, and submit required reports. Reporting obligations include suspicious transaction reports and large virtual currency transaction reports. A large virtual-currency report is generally triggered when a reporting entity receives virtual currency equivalent to C$10,000 or more in one transaction, with aggregation rules applying to linked receipts within a consecutive 24-hour period. The report is generally due within five working days.

Money services businesses also have travel-rule obligations for virtual-currency transfers and may be examined by FINTRAC for compliance. From October 1, 2025, strengthened controls include criminal-record and eligibility reviews for agents or mandataries, with periodic review requirements. Agents engaged before that date are subject to a transition deadline of October 1, 2027 for the initial review.

As of June 25, 2026, the regime is in force. March 26, 2026 amendments require compliance programs to be reasonably designed, risk-based and effective and add stronger administrative enforcement tools, subject to applicable transitional provisions. Separate legislation also contemplates requiring covered stablecoin issuers to register with FINTRAC as virtual-currency MSBs, but that expansion awaits implementing regulations published in the Canada Gazette, Part II. The government anticipates broader stablecoin implementation in 2027, although no fixed commencement date has been set.