MSBs

FINTRAC MSB Registration Revoked or Expired: Causes, Consequences and How to Re-register

Published October 2026 · Last reviewed 20 October 2026 · 10 min read

Key takeaways

  • FINTRAC's registry shows 165 MSB registrations revoked in 2026 up to 16 September, against 23 in 2025; about 76% offered virtual currency services.
  • Grounds for revocation include an unanswered clarification request within 30 days, ineligibility, and failing to notify changes to name or address.
  • Registration expires after two years; FINTRAC says most complete renewals take up to three months, so file well before expiry.
  • Operating unregistered is a serious violation with a maximum penalty of C$4 million per violation since 26 March 2026.
  • A revocation can be reviewed if requested within 30 days; otherwise re-registration is a new, complete application.

A FINTRAC money services business (MSB) registration ends in one of two ways: it expires because it was not renewed within two years, or FINTRAC revokes it. Either way the business must stop offering MSB services in Canada until it is registered again. FINTRAC's published registry data, last updated 16 October 2026, shows 165 registrations revoked with a revocation date in 2026, the latest on 16 September 2026, against 23 in 2025. About 76% of those revoked in 2026 offered virtual currency services.

Since 26 March 2026, operating without registration is also more expensive. Failing to register is classed as a serious violation, with a maximum penalty of C$4 million per violation, and it can lead to criminal charges.

This guide explains why registrations are revoked or expire, what follows for the business and its bank, and how to re-register with a compliance programme that will hold up. For the full registration process, see our guide to Canada MSB registration with FINTRAC.

Revoked, expired, ceased: what each status means

FINTRAC's Money Services Business Registry shows a status for every business that has registered. Each status has a different cause and a different way back.

StatusWhat it meansTypical causeRoute back
RegisteredRegistration is currentNot applicableRenew before the expiry date
ExpiredThe two-year period ended without renewalRenewal form not filed in timeNew registration application
RevokedFINTRAC cancelled the registrationUnanswered clarification request, ineligibility, stale informationReview within 30 days, or a new application once the cause is fixed
CeasedThe business told FINTRAC it stoppedMSB services endedNew application if services restart

The registry data at 16 October 2026 listed 4,191 businesses as registered, 2,584 as expired, 1,629 as ceased and 407 as revoked.

Why FINTRAC revokes MSB registrations

FINTRAC's list of revoked registrations states that it can deny or revoke a registration where the business:

  • is not eligible for registration
  • does not answer a clarification request within 30 days
  • does not respond in time to demands for information from FINTRAC
  • does not notify FINTRAC of updates to its name or address
  • fails to give FINTRAC assistance

A clarification request is a FINTRAC email asking the business to confirm or explain registration information. It goes to the contact person or representative for service on file. If that person has left, or the mailbox is not monitored, the 30 days can pass unnoticed.

Foreign MSBs carry an extra risk. A foreign MSB has no place of business in Canada but serves Canadian customers, and it must name a representative for service who lives in Canada. If the representative's name or address changes and FINTRAC is not told within 30 days, FINTRAC states that the registration will be revoked.

Ineligibility is the other main ground. A business cannot register if it, its chief executive, president, any director or anyone owning or controlling 20% or more has certain convictions, including money laundering, terrorist financing and some fraud and drug offences, or is a listed terrorist or a sanctioned person under specified Canadian laws. A change of director or owner can therefore make a registered business ineligible. See FINTRAC's list of who is not eligible to register.

Why MSB registrations expire

Registration lasts two years. FINTRAC states that it is the business's responsibility to renew before the expiry date and that the majority of complete applications are processed within three months. A renewal filed a few weeks before expiry may not be decided in time.

The registry recorded 262 registrations with an expiry date in 2026 that now show as expired. Common reasons are an expiry date not diarised after a change of compliance officer, a renewal form that was incomplete and closed, and a business that assumed renewal was automatic.

DateAction
Registration plus 20 monthsStart the renewal pack and check every item of registered information
Registration plus 21 monthsFile the renewal form
Within 30 days of any requestAnswer FINTRAC clarification requests
Before the expiry dateConfirm the renewal has been approved

What revocation or expiry means for the business

Once registration ends, the business is unregistered. Offering MSB services in that state breaches section 11.1 of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. For violations after 26 March 2026, the penalty ranges are:

ClassificationMaximum per violation after 26 March 2026Maximum before 26 March 2026
MinorC$40,000C$1,000
Serious, including failing to registerC$4,000,000C$100,000
Very seriousC$20,000,000C$500,000

These figures come from the amended administrative monetary penalties regulations. Bill C-12, the Strengthening Canada's Immigration System and Borders Act, also made compliance agreements mandatory where a penalty is imposed and gave FINTRAC a new power to issue compliance orders. Criminal charges remain possible, although FINTRAC cannot pursue both a penalty and a criminal charge for the same non-compliance.

The commercial effect is often faster than the legal one. Canadian financial entities must confirm that a foreign MSB is registered with FINTRAC before opening an account for it or providing correspondent banking. The registry is public, so banks, payment partners and enterprise customers can see a revoked or expired status at once. Accounts can be frozen or closed while the business is unregistered.

Can a revocation be challenged?

Yes, within limits. FINTRAC gives written reasons for a denial or revocation, and the business can ask for a review of its file within 30 days. A review is worth pursuing where FINTRAC's records are wrong, for example where a clarification answer was sent but not received. Where the underlying failure is real, the faster route is usually a clean new application.

During a review the business remains unregistered. It should stop offering MSB services in Canada until it is registered again.

How to re-register after revocation or expiry

Re-registration is a new application. FINTRAC accepts only complete applications and closes incomplete ones. The steps are:

  • Fix the cause. Answer the outstanding information request, correct the registered details, or remove the person who made the business ineligible.
  • Submit FINTRAC's pre-registration form. A FINTRAC officer then sends the registration form.
  • Build a complete document pack: criminal record checks for the chief executive, president, directors and 20% owners, issued no more than six months before the application; certified English or French translations; incorporation and ownership documents; full details of locations, agents and bank accounts; and, for a foreign MSB, the representative for service.
  • Upload everything through FINTRAC's secure link, which expires after 15 days.
  • Answer any clarification request within 30 days.

Allow for FINTRAC's statement that most complete applications take up to three months. Plan banking conversations around that period rather than assuming a quick reinstatement.

Rebuilding the compliance programme

A revocation is a signal that the compliance programme did not work in practice. Since 26 March 2026 the Act requires the programme to be reasonably designed, risk-based and effective, so re-registering with the same documents is a risk at the first examination.

ElementWhat to rebuild
Compliance officerA named person with authority, time and a deputy who monitors FINTRAC correspondence
Policies and proceduresUpdated for current services, approved by a senior officer
Risk assessmentSpecific to the actual corridors, customers, products, channels and virtual currency activity
TrainingRecords for staff and agents, refreshed after the revocation
Two-year effectiveness reviewAn independent review of policies, risk assessment and training, with findings closed
Registration information controlA change log that triggers a FINTRAC update within 30 days
Agent checksEligibility and criminal record checks before engagement, repeated every two years; agents engaged before 1 October 2025 checked by 1 October 2027

Our compliance support work focuses on these controls, so that the new registration is defensible at examination.

Keeping a registration in good standing

Most revocation grounds are administrative, which means they can be prevented with simple controls. FINTRAC writes to the contact person or representative for service on file and expects a reply within 30 days. It expects changes to be reported within 30 days. It expects renewal before expiry. None of these requires a large team, but each needs an owner.

ControlOwnerFrequency
Monitor the mailbox FINTRAC uses for the contact person, with a named deputyCompliance officerDaily
Log every FINTRAC request with its 30-day response dateCompliance officerOn receipt
Compare registered details (owners, directors, locations, agents, services, bank accounts) with the business as it operatesCompliance officer and company secretaryQuarterly
File a change form within 30 days of any changeCompliance officerOn change
Check that new directors and 20% owners are eligible before appointmentBoardOn appointment
Diary the renewal at registration plus 20 monthsCompliance officerEvery two years
Complete the two-year effectiveness review and close its findingsIndependent reviewer and boardEvery two years
For a foreign MSB, confirm the Canadian representative for service is currentCompliance officerQuarterly

Two further points are often missed. A business that stops offering MSB services must cancel its registration within 30 days, rather than letting it lapse. And copies of documents submitted with a registration application must be kept for at least five years.

Banks and payment partners usually ask for evidence of these controls during onboarding and periodic reviews. Keeping the log and the change history in one place makes those reviews shorter and shows the registration is being actively managed.

FINTRAC registration is one of several Canadian requirements. A business that holds customer funds or moves payments for end users may also need Bank of Canada RPAA registration, with its own annual report due by 31 March 2027; see our RPAA annual report 2027 guide. Quebec runs its own MSB licensing. Virtual currency businesses should also note that stablecoin issuers will register with FINTRAC under the Stablecoin Act. Our page on money services businesses in Canada brings these together.

Frequently asked questions

The business is no longer registered and must stop offering MSB services in Canada. The status shows as revoked on FINTRAC's public registry. Continuing to operate is a violation that, after 26 March 2026, carries a penalty of up to C$4 million and possible criminal charges.

You can request a review of your file within 30 days of the decision. FINTRAC gives written reasons. The business remains unregistered while the review is under way.

FINTRAC states that the majority of complete applications are processed within three months. Incomplete applications are closed, so the full document pack should be ready before the pre-registration form is submitted.

No. Expiry means the two-year registration was not renewed in time. Revocation means FINTRAC cancelled the registration, for example for an unanswered clarification request or ineligibility. Both leave the business unregistered.

FINTRAC's published registry data, updated 16 October 2026, shows 165 registrations with a 2026 revocation date, the latest on 16 September 2026. About 76% of them offered virtual currency services.

Often, yes. Canadian financial entities must confirm a foreign MSB is registered before opening an account or providing correspondent banking, and the registry is public. Banks and partners commonly review or close accounts when a registration is revoked or expires.

Yes. A foreign MSB must tell FINTRAC of any change to the name or address of its representative for service in Canada within 30 days. FINTRAC states that the registration will be revoked or denied if it is not told in time.

References

About Regulatory Counsel

Regulatory Counsel prepares FINTRAC MSB and foreign MSB registrations, renewals and re-registrations, and rebuilds compliance programmes after revocation. We work on the document pack, the programme and the banking conversation together. Every enquiry is answered the same business day with a written proposal: contact us.

This article is general information as at 20 October 2026 and is not legal advice.

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