MSB Registration

MSB Registration Process & Timeline

Registration Timeline

Step 1:
Document Collection (Day 1)

At this stage, you will provide us with basic business information, which we need to form your company, register your MSB/fMSB, and prepare your AML (Anti-Money Laundering) Policies for the Canadian market.

Documents required from you:

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Detailed business plan.

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Questionnaire – Renno's custom MSB/fMSB questionnaire with questions about your intended products, services, delivery channels, geographic locations, clients, and key personnel.

Our Deliverables to you:

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Dedicated Contact 

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Regulatory Advice 

Step 2:
Company Formation & AML Policies
(Duration: 1 week for Company Formation, 7 weeks for AML Policies)

Our Deliverables (1 week):

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Company Formation 

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Corporate Documentation 

Our Deliverables (7 weeks):

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Risk Assessment 

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AML Policy 

Risk Assessment & AML Policies (Duration: 7 weeks)

After you have provided us with the Initial Documentation (i.e. Step 1), we will begin preparing your Risk Assessment and AML Policies. AML policies are vital documents that you will need to operate your fintech in Canada. You will need your Risk Assessment and AML Policy ready for your Bank Account Setup (Step 7), as most reputable banks/neobanks request this as part of their onboarding process.

Step 3:
Pre-Registration Submission (Duration: up to 2 weeks)

At this stage, we make the pre-registration submission to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

Our Deliverables:

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Finalized Business Plan/Amendments

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FINTRAC Representative 

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Submission of Pre-Registration Materials

Step 4:
Waiting for FINTRAC Part 1
(Duration: typically 2-6 weeks)

At this stage, we wait for FINTRAC to approve our pre-registration submission.

Typically, FINTRAC will respond in 1 of 2 ways:

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FINTRAC Credentials: They will provide us (your FINTRAC Representative) with credentials to your online FINTRAC portal. We will then access your FINTRAC portal and make final registration submissions on your behalf.

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Phone Interview: FINTRAC may request a phone interview, which your FINTRAC Representative, Renno professional, will take on your behalf. After this, FINTRAC will provide the credentials to your online FINTRAC portal, which we will access and make the final registration online on your behalf.

Our Deliverables:

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Coordinating with FINTRAC, if necessary

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Accessing your FINTRAC portal to submit your registration

Step 5:
Registration Submission
(Duration: 1-2 weeks)

At this stage, we submit the registration inputs to FINTRAC.

Our Deliverables:

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Submission of Registration Materials

Step 6:
Waiting for FINTRAC Part 2
(Duration: typically 1-3 weeks)

At this stage, we wait for FINTRAC to approve our registration submission.

Typically, FINTRAC will respond in 1 of 2 ways:

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Approval: FINTRAC approves your MSB/fMSB registration!

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Clarification Request: FINTRAC may have questions about your registration submission, which your FINTRAC Representative (from our team) will respond to promptly. After FINTRAC is satisfied with the response, they will approve your MSB/fMSB registration.

Our Deliverables:

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Responding to FINTRAC clarification request, if necessary

Step 7 (Premium Package Option):
Bank Account Setup
(Duration: 2-4 weeks)

At this stage, we help you open a bank account for your fintech. This is an optional service available to Premium package customers.

Our Deliverables:

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Bank Account Setup 

MSB/fMSB Registration Timeline

It will take roughly 8 weeks for the MSB/fMSB registration to be complete and an additional 2-4 weeks to get a bank account.

FAQ

What is the difference between an MSB vs. fMSB?

An MSB requires physical presence in Canada (i.e. a physical location and local representatives working on your behalf). We can help with that.

In contrast, an fMSB is a foreign business that wants to direct and offer its services to Canadians. We can also help with that.

In addition, there also exists practical differences in the registration process and the ability/opportunity to onboard with certain financial institutions.

Find out more at our “MSB Registration page”.

What services can I provide with an MSB/fMSB?

You can provide the following types of services with an MSB/fMSB:
- Forex trading
- Currency exchange
- Cross-border remittance
- Payment services
- Gateway services
- Merchant services
- Issuing or redeeming money orders or traveller’s cheques
- Over-The-Counter crypto trading
- Crypto remittance, payment, gateway, or merchant services

How long does it take to get an MSB registered?

Approximately 2-3 months.

For a more detailed walkthrough of the steps involved, check out our “MSB Registration Timeline”.

Can I “passport” the MSB to other countries?

This is okay from a Canadian regulatory perspective; however, in order to service clients outside of Canada, you will need to comply with the local laws and regulations of that region.

‍Please reach out here if you’d like to learn more about how you can potentially “passport” into foreign jurisdictions.

Can I provide crypto services with an MSB?

Yes, you can provide crypto-related payment services, such as sending, receiving, or OTC exchanging well-established crypto assets (e.g. Bitcoin, Ethereum, Litecoin, etc.). However, you may need to obtain additional expensive registration with securities regulators if you (1) custody your clients’ crypto assets, (2) operate a custodial crypto exchange, or (3) deal with smaller less-established crypto assets.

Please reach out here if you’d like to learn more.

Will I need any other licenses or registrations to operate my fintech company?

You may need to obtain additional expensive registration with securities regulators if you (1) custody your clients’ crypto assets, (2) operate a custodial crypto exchange, or (3) deal with smaller less-established crypto assets.

If you want to operate in the province of Québec or take on Québec clients, you may need an additional MSB license with Revenu Québec. We can help with that! Please reach out here if you’d like to learn more.

Effective November 2024, remittance companies, neobanks, payment service providers, and certain fintech technology providers may need to register under the *Retail Payment Activities Act.*

How much does it cost to get an MSB/fMSB registered?

Whether you are registering an MSB or an fMSB, the cost is the same! For either option, we offer our “Basic” service for $9,500 USD and our “Premium” service for $11,500 USD.

Is there a requirement for MSBs to have a local director?

Not necessarily; however, some financial institutions expect a certain degree of physical presence in Canada and having a local director helps with that.

My MSB/fMSB license expired/got seized, what do I do?

Generally speaking, if your MSB/fMSB registration has expired or ceased, the first step is to reach out to FINTRAC and let them know you’d like to your registration.

Depending on the length of time your registration has lapsed and the reason for the lapsing, you may need to redo your MSB/fMSB registration.

We’ve helped several companies engage with FINTRAC and get their MSB registration back up and running. Please contact us here if you would like to learn more about how we can help.

Is it a requirement for an MSB to have local physical presence or a local representative?

An MSB (not an fMSB) is expected to have physical presence in Canada. According to FINTRAC agents we’ve spoken to, this means that you need a representative of your business who will be working on your business during normal working hours at a private address in Canada.

We can help you establish physical presence in Canada as a part of our Fractional AML offering.

Will the MSB allow me to provide services to non-Canadians?

Canadian regulators have no issue with MSBs servicing non-Canadians. However, in order to service clients outside of Canada, you will need to comply with the local laws and regulations of that region.

Please contact us if you’d like to learn more about how you can potentially “passport” into foreign jurisdictions.

MSB/fMSB Registration

Want to get your MSB/fMSB registered in Canada?