How to Start a Money Transfer Business in Canada: FINTRAC Registration, Québec and Compliance

In Canada, a money transfer business registers rather than applies for a federal licence, and that leads many founders to underestimate the work. Registration with FINTRAC is the easy part. The compliance programme behind it must be running before your first customer, Québec has its own licensing regime, and the reporting and record-keeping duties apply to every transfer from day one.

This guide is for founders, compliance officers and operations leads setting up or running a money services business (MSB) that sends money from Canada. It covers the registrations, the compliance programme, customer identification, reporting, record keeping, sanctions and language. It is general guidance, not legal advice: confirm your obligations with FINTRAC, the provincial authorities and a Canadian adviser before you launch.

Remitting or transmitting funds is an MSB activity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). A business doing it in Canada must register with FINTRAC before it starts, and a business outside Canada that serves people in Canada must register as a foreign MSB. Provincial rules and federal payments law can add further steps.

Québec is currently the only province that regulates MSBs itself. British Columbia passed a Money Services Businesses Act in 2023 that will require registration with the BC Financial Services Authority once it is brought into force, so check its status if you serve customers there. Provincial consumer protection and privacy rules apply everywhere. Whether the Retail Payment Activities Act covers you depends on your model, so get a view on it early, especially if you plan to let customers hold a balance.

FINTRAC expects a compliance programme that works in practice, not a binder of documents. FINTRAC's guidance sets out six requirements, which come to five things to build:

1. A compliance officer with the authority and resources to run the programme.
2. Written policies and procedures, kept up to date and approved by a senior officer.
3. A risk assessment of your money laundering and terrorist financing risks: customers, corridors, delivery channels, products and new technology.
4. A written, ongoing training programme for staff and anyone acting on your behalf, with a documented plan for delivering it.
5. An effectiveness review at least every two years, with a documented plan, that tests whether the policies, risk assessment and training work, with findings reported to senior management.

Examiners compare what your policies say with what your system does. If the policy says transfers above a certain total need source-of-funds evidence, they will expect to see the platform ask for it. Write the programme with the platform's configuration open in front of you. For the wider structure, see compliance and risk management for money transfer businesses and managing recurring compliance training.

The PCMLTFA sets when you must verify a customer's identity and which methods are acceptable, such as government-issued photo identification or credit file and dual-process methods. For an MSB, expect duties to:

• Verify identity before or at the point required, using an accepted method, and record how you did it.
• Make third-party determinations when someone may be acting on another person's instructions.
• Determine politically exposed persons and heads of international organisations, and their family and close associates, where required.
• Identify beneficial owners of business customers.
• Monitor the business relationship on an ongoing basis, with enhanced measures for higher-risk customers.
• Send the required information with each transfer, so that originator and beneficiary details travel with the funds.

The practical challenge is timing. Ask for everything at sign-up and many genuine customers leave; ask too little and you breach the rules. Tie checks to the first transfer, and ask for more documents only as a customer's activity grows.

Reporting is where most new MSBs feel the workload. Described generally, the reports are:

The 24-hour rule is what catches people out. Several smaller transfers by or for the same person can together cross the threshold, so your system must be able to group them. Ministerial directives can also impose extra measures on transactions involving particular jurisdictions. For how to build a suspicious activity case, see our guide to suspicious activity reports.

An MSB must keep records of identity verification, transfers above the record-keeping thresholds, reports filed, the compliance programme and training. Records generally have to be kept for at least five years and produced within the period FINTRAC sets when it asks. In practice, keep:

• Every transfer with sender, recipient, amounts, rate, fee and status history.
• Each identity check: the method, the document and who reviewed it.
• Every screening result and the decision made on it.
• Every suspicious activity case, including the ones you decided not to report, and why.
• Training records showing who completed what, and who signed it off.

Records that live in one system, linked to the transfer they relate to, are far quicker to produce during an examination than records spread across email and spreadsheets. See also preparing for your first regulatory audit.

Canada's autonomous sanctions are imposed mainly under the Special Economic Measures Act (SEMA) and the Justice for Victims of Corrupt Foreign Officials Act, alongside regulations implementing UN Security Council sanctions and the Criminal Code's list of terrorist entities. If a customer or recipient matches, you may have to freeze the property, disclose it to the authorities named in the law and file the relevant FINTRAC report.

Decide which lists you screen against, who rules on a possible match, and what happens to the transfer while they decide. Re-screen existing customers whenever a list changes; a customer cleared last month may be listed today. For screening design, see sanctions screening for remittance companies.

Québec's Charter of the French Language sets expectations for how businesses communicate with consumers in Québec, including contracts, product information and digital services. Outside Québec, many of your customers will still prefer French. Plan for:

• The app, emails, receipts and terms available in French.
• Scam warnings and compliance requests (for documents or source of funds) that customers understand, in their language.
• Support staff who can handle a French-language complaint.

Our guide to launching an app in your customers' language covers the rollout.

The details are illustrative, not drawn from any real operator. A Toronto-based team of six sends money to two corridors, through bank deposit and mobile wallet payouts.

Month 0. The compliance officer writes the programme against the platform's configuration: a CAD AML rule asking for proof of address once a customer's 90-day total passes a set level, and source of funds above a higher annual total. Training is assigned to all six staff and signed off by someone other than the trainee. The business registers with FINTRAC.

Month 4. Sign-ups from Montréal grow. Before marketing there, the team checks with an adviser and Revenu Québec, applies for the Québec licence, and switches the app and emails to French for customers who choose it.

Month 7. A customer sends three transfers in one afternoon that together exceed CAD 10,000. The risk rule combining transaction frequency and volume holds the third for review. The compliance officer confirms the grouping, prepares the electronic funds transfer report and records the decision.

Month 9. An overnight load of the Canada SEMA list adds new names. Affected customers and recipients are re-screened; one possible match is ruled a false positive by the compliance officer, with the reasons kept.

RemitSo is a white label remittance platform. It gives a Canadian MSB the controls and records its compliance programme describes. See the admin features.

• Sanctions screening against 8 lists reloaded every night, including Canada SEMA and the UN list. Each list shows its version and load history, people a change could affect are re-screened, officers' decisions are recorded, and alerts such as "Sanction lists out of date" and "Possible sanction match found" reach the right people.
• AML rules per currency, including CAD, with windows from a single transaction to a year, corridor exceptions and document tiers as totals grow, plus a history of changes.
• 46 risk indicators, such as transaction frequency and volume and linked transaction patterns, combined into your own rules: risky transfers wait for a person.
• Suspicious Activity Reports generated, managed and submitted from the console, keeping each case with its evidence.
• ID check and selfie inside the first transfer, with reviewer overrides and reasons kept.
• Apps in English, French or Spanish, with emails in each customer's own language, for customers in Québec and across Canada.
• Staff training with proof, available as an optional add-on: assign, remind and sign off, and nobody signs off their own.
• A dedicated AWS account in your region, a software bill of materials, and ISO 27001:2022 and ISO 9001:2015 certification for bank, partner and regulator technology reviews.

RemitSo does not produce FINTRAC reports today; its only built-in regulator report is Australia's IFTI-E. Your team still owns the programme, decides what is reportable, files with FINTRAC and handles Québec licensing.

Operators planning EU expansion can read our guide to the EU payment institution licence and passporting. Book a demo to see the controls against your own programme.

• Justice Laws Website: Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• FINTRAC: Money services businesses and foreign money services businesses (who must register, agents)
• FINTRAC: Compliance program requirements
• FINTRAC: Methods to verify the identity of persons and entities
• FINTRAC: Reporting suspicious transactions to FINTRAC
• FINTRAC: Reporting large cash transactions to FINTRAC
• FINTRAC: Reporting electronic funds transfers to FINTRAC
• FINTRAC: Travel rule for electronic funds and virtual currency transfers
• FINTRAC: Record keeping requirements for money services businesses
• Revenu Québec: Money-Services Business Licence Application and the Money-Services Businesses Act (Québec)
• Bank of Canada: Retail payments supervision (Retail Payment Activities Act)
• Government of British Columbia: announcement of the Money Services Businesses Act
• Global Affairs Canada: Canadian sanctions legislation and Public Safety Canada: Listed terrorist entities
• Charter of the French Language (Québec), chapter C-11

Checked October 2026. Regulations change; confirm current requirements with the regulator or your adviser.