FINTRAC Registration
Over the past few months, we have heard from several money services businesses (MSBs) that have experienced issues in renewing their MSB registrations with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). In most cases, these issues are easily resolved. However, if MSB registration issues are not addressed promptly, administrative monetary penalties (AMPs) or criminal charges may ensue.
It is likely that registration-related issues have become more common as FINTRAC is increasingly requesting additional information or clarifications from MSBs as part of the initial registration and registration renewal process. These requests are sent via email to the contact person listed in the MSB registration form.
Check Your MSB registration Status
You can view the status of your MSB registration by searching for your business on the public MSB registry. While this article is about the MSB registration status, anytime you are on this page, it is a useful practice to check to ensure that all of the information is up to date. There are several possible options for the “Registration status of MSB” field:
Registered: this is the status that is displayed for active MSBs. The detailed view will also show the expiry date of the registration.
Ceased: this status is displayed when an MSB has cancelled their registration (e.g. because the business is no longer conducting MSB activity or is only performing MSB activity as the agent of another MSB).
Expired: this status is displayed when an MSB has not submitted an MSB registration renewal on time, has not responded to requests for information from FINTRAC, or has not provided sufficient information to FINTRAC to complete the renewal process.
Revoked: this status indicates that FINTRAC has revoked an MSB’s registration.
If the Expiry Date is Coming Up Soon
If you notice that your MSB’s registration is expiring soon, there are several steps that you should take proactively. First, make sure that you have your login credentials and access FINTRAC’s secure MSB Registration portal. On the left-hand side of the screen, you may see an option to submit your renewal application. If this option is not yet present, it is still a useful practice to select “view completed form” and review the MSB information to ensure that everything is up to date. If there is anything that needs to be updated, you can update the form (information must be updated within 30 days of any changes; do not wait for the renewal date to make updates).
If the renewal can be processed at this time, make sure that you take the time to look at all data fields. Are these fields complete and accurate? Does the information related to the MSB’s beneficial ownership match what will be found in any corporate registries (if not, additional information and/or correction may be required before the registration can be processed). FINTRAC may request additional information by email, and your registration will not be renewed until these queries have been satisfied.
If the Registration is Expired
If you notice that your registration has expired, you should immediately access FINTRAC’s secure MSB Registration portal to renew it. It may be that you have simply missed a deadline, or that you did not notice an error message or request for additional information from FINTRAC. Whatever the cause, you should work to resolve the issue and renew the registration as soon as possible.
If you are not able to renew the registration, contact FINTRAC immediately by emailing guidelines-lignesdirectrices@fintrac-canafe.gc.ca and MSBRegistration@fintrac-canafe.gc.ca immediately with the subject line “URGENT – MSB Renewal Issue – Renewal Date Passed”.
- In the body of the email, let them know:
- The company name and MSB number
- That you have been attempting to renew the MSB registration
- If you have responded to any requests for additional information, the details of these correspondences (attach copies if possible)
- Ask what information is needed at this stage to renew the MSB registration
Keep a copy of this and all communications with FINTRAC.
You may also want to consider making a voluntary self-declaration of non-compliance (VSDONC) to FINTRAC. For help with disclosures, check out our previous blog post.
If you receive a “Notice of Violation”
Where an MSB registration is expired, and the MSB continues to perform MSB activities (other than as an agent for another MSB), a penalty may be assessed, and a “Notice of Violation” may be issued. At this stage, a law firm should be engaged (we’re happy to recommend competent firms if this is something that you need). There are specific and relatively short timeframes for all response steps, and this should be treated as urgent.
We’re here to help.
If you are not sure what to do next or need assistance with compliance, please get in touch.